Copley Financial Group Inc

Item 5: Fees and Compensation
 Method of Compensation and Fee Schedule
 ASSET MANAGEMENT
 Advisor offers direct asset management services to advisory clients. The fees for these services
 will be based on a percentage of assets under management as follows:

    Assets Under Management         Annual Advisory Fee               Admin Fees        Advisor
         $100,000 or less           $1,450 Minimum Fee                $450/Annual   $1,000/Annual
          Over $100,000                    1.45%                        .45%              1%

 The annual fee may be negotiable. Accounts within the same household may be combined for a
 reduced fee. Advisor will charge an advisory fee based on the above schedule for the services we
 provide.
 As part of a client’s overall portfolio Advisor may recommend you invest in fee-based alternative
 investments. Advisor charges a flat annual fee of 1% on fee-based alternative investments. The
 account value of the alternative investments will not be included in the account householding for
 calculating fees for other accounts managed by Advisor.
 Fees are billed monthly in arrears based on the amount of assets managed as of the close of
 business on the last business day of the month. For clients invested in fee-based alternative
 investments, fees will be billed monthly in arrears based on the initial investment.
 Advisor may also utilize the services of a Sub-Advisor to manage Clients’ investment portfolios by
 executing a Sub-Advisor agreement with other registered investment advisor firms. When using
 Sub-Advisors, the Client will not pay additional fees, the fees are inclusive of fees charged by
 Advisor. Sub-Advisor may directly deduct their portion of the fee separately from Advisor.
 Monthly advisory fees will be deducted from the clients' account by the custodian. The fees must

                                       Copley Financial Group, Inc.

be paid within ten (10) days following the beginning of the month which the account is being
billed for. Lower fees for comparable services may be available from other sources. Advisor may
also utilize the services of a Sub-Advisor to manage Clients’ investment portfolios by executing a
Sub-Advisor agreement with other registered investment advisor firms. When using Sub-
Advisors, the Client will not pay additional fees, the fees are included in the fee charged by
Advisor. The sub-advisor fee will be disclosed to and acknowledged by the Client in Advisor’s
Investment Advisory Agreement. Sub-Advisor may directly deduct their portion of the fee
separately from Advisor.
For accounts that utilize GeoWealth Management LLC as a Sub-Advisor, accounts will be billed
monthly in arrears based on the average daily balance of the account.
CO-ADVISOR FEES
Advisor has entered into a Co-Advisor Agreement with the following Third-Party Money
Managers (TPM).
Gradient Investments, LLC (GI)
GI is a Registered Investment Advisor registered with the Securities and Exchange Commission
that provides investment portfolio advice and supervisory services.
GI offers an actively managed program of mutual fund and stock portfolios. The fee will be
disclosed to the client in the Investment Advisory Agreement and are negotiable. The client’s fee
for these services will be based on a percentage of assets under management as follows:
    STRATEGIC PORTFOLIOS
                                Annual Fee                      GI                Advisor
    All Assets                    1.70%                       0.70%                1.00%

    TACTICAL PORTFOLIOS
                                 Annual Fee                   GI                 Advisor
    All Assets                       1.65%                  0.65%                  1.00%
Traditionally, GI’s Tactical Portfolio was billed with a max annual fee of 2.00%. Since GI is the sub-
advisor to the Tactical Portfolio and will receive an annual fee of 0.20% from the ETF, GI has
reduced its annual fee of the Tactical Portfolio so as not to double dip.
For example, a Client investing $100,000 in the GI Tactical portfolio prior to November 2022
would pay an annual fee to GI of $2,000 or $100,000 x 2.00% = $2,000. After November 2022 the
same client would pay GI an annual fee of $1,650 or $100,000 x 1.65% = $1,650 and pay the
internal fees of $200 or $100,000 x 0.20% = $200. For a total of $1,650 + $200 = $1,850.
    ALLOCATION & DEFINED OUTCOME PORTFOLIOS
                         Annual Fee           GI                                  Advisor
    All Assets             1.55%            0.55%                                  1.00%

    PRESERVATION PORTFOLIOS
                        Annual Fee                              GI                Advisor
    All Assets            1.00%                               0.40%                0.60%

    CLIENT DIRECTED ACCOUNTS
                         Annual Fee                             GI                Advisor

                                      Copley Financial Group, Inc.

    All Assets                     $300                        $300                     $0
For Client Directed Accounts (CDA), GI will assist in the opening, closing and transferring of
accounts. GI will not have discretion at any time on these accounts. Client is solely responsible for
the assets held within the accounts and their values which could increase or decrease (potential
loss of principal). GI will not execute trades in CDA accounts. GI exceptions will be made for
withdrawals to client or assets transferred into a GI managed portfolio. GI will also provide
performance reporting on these accounts and can furnish 3rd party analysis reports per the
client’s request. Similar services may be available through other sources for a lower fee.
These are flat fee schedules, the entire portfolio is charged the same asset management fee.
Example:
  Portfolio                                         Calculation                 Quarterly Fee
...

Item 7: Types of Clients
 Description
 Advisor generally provides investment advice to individuals and pension and profit sharing plans.
 Client relationships vary in scope and length of service.

 Account Minimums
 Advisor requires a minimum of $100,000 to open an account, however the minimum may be
 waived at Advisor’s discretion.