Item 5: Fees and Compensation
A. Users of the Website will not pay a fee to Adviser if the recommended investment and financial action
items are to be implemented solely by the user (and not by Adviser). If a user wants Adviser to
implement the recommended investment and financial action items through the Website, Adviser will
charge a recurring monthly fee of $24 per month, payable in arrears via ACH, debit card, or credit card.
Such fees are not negotiable, charges may evolve and change over time, and updates to this brochure
will be made accordingly.
B. In addition to the fees charged by Adviser, users will incur brokerage and other transaction costs.
Please refer to Item 12: Brokerage Practices, for further information on such brokerage and other
transaction-related practices. Users will also typically incur additional fees and expenses imposed by
independent and unaffiliated third-parties, which can include qualified custodian fees, mutual fund or
ETF fees and expenses, mark-ups and mark-downs, spreads paid to market makers, wire transfer fees,
check-writing fees, early-redemption charges, certain deferred sales charges on previously-purchased
mutual funds, margin fees, charges or interest, IRA and qualified retirement plan fees, and other fees
and taxes on brokerage accounts and securities transactions. The Independent Partners will also
charge their own fees and costs to users pursuant to their respective agreements and fee schedules.
These additional charges are separate and apart from the fees charged by Adviser.
C. If the agreement between a user and Adviser is terminated before the end of a monthly billing period,
Adviser will not charge a fee for the final month of services.
D. Neither Adviser nor any of its supervised persons accepts compensation for the sale of securities.
However, Adviser will be compensated by certain Independent Partners through various referral and/or
revenue sharing arrangements that will be dependent upon users purchasing a particular product or
using a particular service of such Independent Partners through the Website. By way of example, it is
envisioned that (i) Independent Partner banks will agree to pay Adviser a referral fee for Adviser’s users
that become lending clients of such banks, (ii) Independent Partner Mortgage companies will agree to
pay Adviser a referral fee for Adviser’s users for mortgages, refinancing, and HELOC’s that become
lending clients of such mortgage companies (iii) Independent Partner Insurance companies will agree
to pay Adviser a referral fee for Adviser’s users that become clients of such insurance companies (iv)
certain Independent Partners will pay Adviser an advertising fee to place a clickable advertisement on
the Website, and (v) certain Independent Partners will pay Adviser to have their financial products
available as part of the Website’s universe of recommended financial products and action items. Such
arrangements will likely evolve and change over time, and updates to this brochure will be made
accordingly. Regardless, all such arrangements create a conflict of interest due to the financial incentive
that Adviser has to incorporate such Independent Partners’ products and services into the Website and
to recommend them to users. Adviser addresses these conflicts of interest by providing full disclosure
in this brochure and the Website, by performing independent evaluations of Independent Partners to
assess their appropriateness for users’ financial situations, by periodically evaluating alternative
Independent Partners to recommend, and by always acting as a fiduciary in the best interests of its
users.