Capita Financial Network LLC

Item 5 Fees and Compensation
Capita charges fees based on a percentage of assets under management, payable
quarterly in advance as specified in the client’s investment advisory agreement. Fees
generally range from 1% to 1.75% annually, but Capita may negotiate fees at its
discretion. Fees are charged by account and clients with multiple accounts may be
charged different fee rates for each account as agreed upon in the investment
management agreement. Clients may pay different fees for accounts with the same or
similar objectives at the adviser's discretion. Capita generally directly debits client fees.
However, clients have the option to be billed.

If an advisory agreement is terminated, and/or if a client takes a distribution over $5
before the end of the quarter, Capita will provide the client with a pro-rated refund of
any pre-paid advisory fee. If a client terminates mid-quarter, prepaid fees will typically
be refunded the month following termination. For example, if a client terminated in
April, the client will likely be refunded any prepaid fee in May. If a client deposits
additional funds into an account during the quarter, fees will be charged on pro-rata
basis, factoring in the number of days left in the quarter.

Certain supervised persons of Capita serve as insurance agents. As part of a financial
plan, Capita may recommend the purchase of fixed annuity products and life
insurance. Capita may conduct insurance business under the name “Capita Insurance
Agency” in order to comply with some states’ regulations and standards. Capita
receives commissions on the sale of these insurance products. No client is under any
obligation to purchase a commission product from Capita. Clients may purchase
insurance products recommended by Capita through other non-affiliated insurance
agents. The sale of commission products creates a conflict of interest because Capita
has a financial incentive to recommend these products based on the compensation to

be received, rather than on a client’s needs. In addition to disclosing this conflict of
interest to clients, all supervised persons of Capita must abide by a Code of Ethics
which requires them to make recommendations only in the best interest of their clients.

Clients may also incur charges for brokerage commissions and transaction fees for
effecting certain securities transactions (e.g., transaction fees are charged for certain
no-load mutual funds, commissions are charged for some individual equity and debt
securities transactions) custodian fees, account maintenance fees, fees related to
mutual funds and exchange traded funds, and variable annuities, and other product-
level fees. While Capita generally recommends no-load or institutional share classes
for mutual fund investments, Capita may recommend that a client continue to hold
previously purchased mutual fund shares which may incur additional fees, such as
distribution and redemption fees.

Client assets that are invested in private funds, including funds of funds, are subject to
management fees, performance fees, platform fees and other expenses charged by
such funds as set forth in the offering documents. Such charges and fees are exclusive
of, and in addition to, Capita’s fees. Please see Item 12 for additional information
regarding Capita’s brokerage practices.

Item 7 Types of Clients
Capita provides investment advisory services to individuals (including trusts, estates,
and IRAs of individuals and their family members), high net worth individuals, 401K
plans and small businesses.