BMO Nesbitt Burns Securities Ltd

ITEM 5 FEES AND COMPENSATION
Advisory Services and Fees for Specific Clients
NBSL charges clients annual fees for discretionary investment advisory services based on the market value of assets in the
client’s account. The maximum annual fees range from 125 basis points to 150 basis points depending on the strategy the client
selects. The annual fees are tiered and the actual rate paid by clients will depend on the amount invested by the client. Based
on a variety of factors, NBSL has discretion to discount the annual fees charged to clients. NBSL and the client must agree to the
annual fee charged to the client and the IPS will reflect such annual fee. However, NBSL’s fees are negotiable and can vary.

                Standard Management Fees for                                      Standard Management Fees for
                Balanced and Growth Portfolios                                          Income Portfolios

   Value of Assets                        Annual Fee                  Value of Assets                        Annual Fee
   First $500,000                            1.50%                    First $500,000                            1.25%
   Next $500,000                             1.00%                    Next $500,000                             0.75%
   Next $1 million                           0.60%                    Next $1 million                           0.50%
   Next $3 million                           0.55%                    Next $3 million                           0.45%
   Next $5 million                           0.45%                    Next $5 million                           0.35%
   Balances over $10 million                 0.40%                    Balances over $10 million                 0.30%
   Minimum Investment             $50,000 minimum for                 Minimum Investment             $50,000 minimum for
                                  retirement Accounts;                                               retirement Accounts;
                                  $5,000 minimum for                                                 $5,000 minimum for
                                  non-retirement Accounts                                            non-retirement Accounts
   Minimum Annual Fee             No minimum for Retirement           Minimum Annual Fee             No minimum for Retirement
                                  Accounts;                                                          Accounts;
                                  $5,000 minimum for                                                 $5,000 minimum for
                                  no-retirement Accounts                                             no-retirement Accounts

Either the client or NBSL may terminate the account agreement at any time upon receipt of written notice. If the client
terminates the account agreement within five days of entering into the agreement, then NBSL will not charge the client any
management or administrative fees. The client will receive the market value of their managed portfolio including any realized
market gains or losses. In the event of termination by NBSL or the client during the contract year, the management fee is
refundable on a monthly pro rata basis.

Billing and Payment of Client Fees
Unless otherwise agreed to by NBSL and the client, fees are debited on the 15th business day following the end of the applicable
billing period, either monthly or quarterly depending on the agreement between NBSL and the client.

NBSL calculates the fees using the account average daily balance unless otherwise agreed to by NBSL and the client.
The account average daily balance is the average daily market value of assets held in the account as of the close of each
business day. NBSL bills fees monthly or quarterly based upon client selection and bills the fee on the 15th business day of the
month following the end of the billing month or billing quarter.

Additional Client Expenses and Fees
All clients will incur charges from custodians and other third parties, such as mutual fund level charges, odd-lot differentials,
transfer taxes, wire transfer and electronic funds fees, and other fees and taxes on brokerage accounts and securities
transactions. All fees paid to NBSL for investment advisory services are separate and distinct from the fees and expenses
charged by ETFs or mutual funds to their shareholders. Each ETF or mutual fund describes its fees and expenses in the ETF’s or

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fund’s prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee
(for mutual funds, often referred to as a Rule 12b-1 fee). As a result, clients who engage NBSL to provide advisory services for
a fee, and who have a portion of their assets invested in ETFs or mutual funds are paying two management fees. NBSL charges
the first fee directly for the management of the client’s portfolio, and the ETF(s) or mutual fund(s) charge the second fee for
the management of the ETF’s or mutual fund’s assets. Such charges, fees, and commissions are exclusive of and in addition to
our fees. NBSL receives a portion of the 12b-1 fees you pay to the fund company. The receipt of 12b-1 fees is a conflict to your
interests because NBSL is incentivized to include funds where NBSL receives a 12b-1 fee rather than based on the client’s needs.
We mitigate this conflict by requiring our Investment Advisers to act in their clients’ best interest and disclosing the conflict in
this brochure. For further information regarding our brokerage practices please see Item 12 below.

Advisory Fees in General:
Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered)
investment advisers for similar or lower fees.
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ITEM 7 TYPES OF CLIENTS
NBSL provides advisory services to individuals, trusts, entities, and retirement accounts. The minimum account size is $500,000
and $50,000 for retirement accounts. However, at NBSL’s discretion, it may reduce the account minimum if the client meets
certain criteria (e.g., anticipated future assets, dollar amount of assets under management, related accounts, etc.)

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BMO Nesbitt Burns Securities Ltd. Advisor Brochure

ITEM 8 METHOD OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
NBSL Investment Adviser Representatives select investments for their clients from a broad spectrum of products based on the
client’s investment objectives and risk tolerance. NBSL Investment Adviser Representatives will offer their clients equities, fixed
income, mutual funds, and ETFs depending on client need and preference. NBSL Investment Adviser Representatives attempt
to select investment strategies that are appropriate for the needs of their clients and consistent with the clients’ investment
objectives, risk tolerance, and time horizons, among other considerations.

Investing involves risk, including possible loss of the client’s principal. The client should be prepared to bear these risks.
Investments are not deposits or obligations of, or endorsed or guaranteed by NBSL, BMO Nesbitt Burns Inc., BMO, BMO Bank
N.A., or any other NBSL affiliate. Investments are not insured or guaranteed by the FDIC, the Federal Reserve Board or the U.S.
government or any U.S. government agency. As in all securities investments, past performance does not guarantee future
results. An Investment Adviser Representative who has been successful in the past may not be able to replicate that success in
the future.

Risks Associated with Investing
Asset Allocation Risk: Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of
investment types, industries, and/or market sectors based on the client’s investment goals and risk tolerance. However, a risk of
asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another
risk is that the ratio of investments will change over time due to market movements and, if not rebalanced, will no longer be
appropriate for the client’s goals.

Management and Strategy Risks: An advisory account may not achieve its investment objective. The ability of a portfolio to
meet its investment objective directly relates to the investment strategy for the portfolio. The investment strategy used could
fail to achieve the investment objective and cause investments to lose value.

Data Risk: Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell,
the rating agencies that review these securities, and other publicly available sources of information about these securities, are
providing accurate and unbiased data. While we try to be alert to indications that data may be incorrect, there is always a risk
that inaccurate, incomplete or misleading information may compromise our analysis.

Liquidity Risks: Liquidity risk refers to the possibility that an account may not be able to buy or sell a security at a favorable
price or time. Consequently, the account may have to accept a lower price to sell a security, sell other securities to raise cash, or
give up an investment opportunity, any of which could have a negative effect on the account’s performance. Infrequent trading
of securities also may lead to an increase in their price volatility.

Mutual Funds Risks: Mutual funds are subject to investment advisory, transactional, operating, and other expenses. Each
mutual fund is subject to specific risks, depending on its investments. The value of mutual funds’ underlying investments and
the net asset value of mutual funds’ shares will fluctuate in response to changes in market and economic conditions, as well as
the financial condition and prospects of companies and other investments in which the funds invest. NBSL does not control the
underlying investments in mutual funds. The performance of each fund will depend on whether the fund’s portfolio manager is
successful in pursuing the fund’s investment strategy. For a complete description of risks associated with the individual mutual
funds, clients should refer to the prospectuses and statements of additional information. In addition, as we do not control the
underlying investments in a fund, managers of different funds held by the client may purchase the same security, increasing the
risk to the client if that security were to fall in value. There is also a risk that a manager of the fund may deviate from the stated
mandate or strategy of that fund, which could make the holding(s) less appropriate for the client’s portfolio.

Risks Associated with Equities
Client accounts with all or a portion of the underlying assets invested in equities or equity-based mutual funds, are subject to
the following risks:

Stock Market Risks: Investments in equity securities are subject to fluctuations in the stock market, which has periods of
increasing and decreasing values. Stocks are historically more volatile than debt securities.

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Growth Style Risks: A growth stock is one whose revenues and earnings are expected to increase at a faster rate than the
average company within the same industry. Due to their relatively high valuations, growth stocks are typically more volatile than
value stocks. Further, growth stocks may pay lower dividends than value stocks or may not pay dividends period. This means
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