CFO Capital Management LLC

Item 5 – Portfolio Management Fees and Compensation

Our fees for portfolio management services are based upon a percentage of assets under management.
Depending on the investment objective and the managing IAR, CFO annual management fees will range from
0.7% to 1.9%. Each client’s portfolio management fee is negotiated individually and will be documented in CFO’s
Investment Management Services Agreement [IMSA] that is specifically tailored to each client’s portfolio needs
and goals. CFO does not manage investment portfolios on a non-discretionary basis; and neither CFO nor any
affiliated Investment Advisor Representative [IAR] will ever receive commissions from trades made for managed
client accounts. For the portfolio management services provided to clients by CFO and the IAR, the only source
of compensation paid to CFO and the IAR is from the management fees paid by the client to CFO. Please also
request a copy of CFO’s client Investment Management Services Agreement [IMSA].

Footnotes to the CFO Schedule of Investment Management Fees (above):

(1) CFO manages investment portfolios using four basic portfolio investment objectives: conservative
appreciation; balanced growth; income & growth; and income only. These investment objectives are classified
according to the target allocation of investment capital between bonds/ fixed income securities or investments
for which the primary goal is "current income" and stocks or equity investments for which the primary goal is
"growth". The target allocation between fixed income securities and equity investments respectively ranges
from 100% fixed income securities and 0% for stock/ equity investments for the "Income Only" investment
objective to as high as 100% stock/ equities and 0% bonds for the "Conservative Appreciation" investment
objective.

(2) CFO reserves the right to waive minimums for account size and for annual fees for those managed accounts
with AUM of less than $250,000 in total value (AUM). This (waiver) policy is most often followed for CFO clients
with multiple managed [family] accounts.

(3) As also reported in Section 6 of the CFO IMSA, the above schedule of CFO management fees does not include
certain customary fees imposed by third parties other than CFO in connection with transactional and custodial
services made through the brokerage account. Neither CFO nor its IARs receive any remuneration whatsoever
from brokerage transaction fees or any other third-party custodial account servicing fees. The designated
custodian may charge customary fees for providing routine custodial services. The designated custodian may
have its own fee schedule for transaction services and other ancillary custodial account services, which fee
schedule shall be provided to the client. Also, ancillary custodial account fees are charged for servicing items
such as account transfers, wire requests, security reorganizations, custodial fees for retirement accounts,
retirement account transfers or conversions, banking services, etc.

In addition to custodial fees/ costs and our CFO management fees outlined above, there are other fees and costs
related to our investment advisory services and investments that you may pay directly or indirectly. Examples of
the most common investment fees and costs are ETF and mutual fund fees and those fees charged by the
managers of Alternative Investments such as non-tradeable REITs. Whenever possible for mutual fund
investments made within our discretionary [fee] managed investment accounts, CFO will utilize institutional
class shares that carry the lowest available expense ratios and without any 12b-1 expenses paid to CFO or our
investment advisors.

CFO collects client investment advisory fees on a quarterly basis in arrears. Investment management fees are
prorated for each capital contribution and withdrawal made during the applicable calendar quarter (except for
de minims contributions and withdrawals). Accounts initiated or terminated during a calendar quarter will be
charged a prorated fee. Upon termination of any account, any earned but unpaid fees will be due and payable.

The client will always maintain full control of their account by being able to directly notify the brokerage
company(s) that are holding the client's assets of any actions the client may wish to take place in his or her
account. The client may - for any reason at any time - terminate his contract with the firm.

Item 7 – Types of Clients

CFO provides or will provide portfolio management services for taxable accounts such as to individuals, high net
worth individuals, trusts, estates, and corporations or other business entities. CFO also provides or will provide
portfolio management services for non-taxable [or qualified] accounts including various types of IRAs and ERISA
accounts such as pension and profit-sharing plan accounts for small business owners. CFOdoes not provide

investment advice to ERISA plans, but to the individuals who may have investment accounts that may be part of
ERISA plans.

Item 8 – Methods of Research Analysis, Financial/ Investment Strategies and Risk of Loss

CFO may utilize the following methods of security analysis:
           • Charting - (analysis performed using patterns to identify current trends and trend
                reversals to forecast the direction of prices)
           • Fundamental - (analysis performed on historical and present data, with the goal of
                making financial forecasts)
           • Technical – (analysis performed on historical and present data, focusing on price and
                trade volume, to forecast the direction of prices)

CFO may utilize the following investment strategies when implementing investment advice given to
clients:

            •   Long Term Purchases (securities held at least a year)
            •   Short Term Purchases (securities sold within a year)
            •   Trading (securities sold within 30 days)
            •   Option writing, including ONLY the purchase of Puts and Calls or the sale of Calls only
                for client-owned securities. The sale of uncovered options or the writing of “naked”
                Puts or Calls is not permitted by CFO
            •   Margin Transactions (on a limited basis but not for discretionary management
                portfolios).

In addition to the considerable amount of independent research from companies such as Ned Davis Research,
Morningstar, Bloomberg, Standard & Poor’s, PIMCO, Nuveen and Fidelity Investments, CFO may purchase
and/or review research and analysis from other investment companies on an ongoing basis.

Please Note the Following about Investment Risk:
As directed by the client, a CFO IAR will review, analyze, recommend, and develop an investment plan or plans
for the portfolio management of the client’s assets. The subsequent portfolio management actions by the IAR
and CFO shall be directed toward achieving the client’s investment objectives within the risk tolerance
limitations as defined by the client’s Risk Assessment Profile [RAP] and by other documentation collected and
prepared as part of the CFO client engagement process.
The IAR/ CFO team is interested in helping clients to get where they want to be in three to five years and then
three to five years after that. We aim for real growth - measured in relative terms against inflation - through the
consistent compounding of positive returns over time rather than the expectation of overnight results. Our
approach stresses the importance of sound asset allocation strategies that protect current investment capital
while building wealth for higher levels of long-term prosperity.

With the best of CFO portfolio management efforts notwithstanding, the client understands and accepts that
investment decisions made for the client's managed account(s) by the IAR/ CFO investment team are subject to

various market, currency, economic, (geo-) political, pandemic and business risks that are not controllable by
the IAR or CFO, and that investment decisions may not all be profitable, particularly in the short-term. The client
understands that investments, excepting some forms of cash equivalents, whether in mutual funds, exchange
traded funds, stocks, bonds, or other securities all entail some degree of the risk for loss. The client further
understands that asset category allocation – or diversification - can often mean that some investment purchase/
sale decisions made by CFO / IAR may result in profits and others in losses. Collectively therefore, the client
understands, and accepts, that the IAR/ CFO team cannot guarantee that a client’s investment objectives will be
realized in the short-term, or most critically over any one to three-year or short-term time horizon, and that
positive portfolio performance in the past does not provide any guarantee of equal or better investment results
in the future.