Cresap Inc

Item 5 Fees and Compensation

       Level fees charged on advisory accounts are based on the value of the account, and are
expressed on an annualized basis. This is explained in greater detail below.

       The amount of the advisory fee is set by agreement between the advisor and the client.
This applies to any fee based advisory account at the firm.

       With respect to non-discretionary (client directed) fee based accounts there are two
options currently offered by Cresap Inc. to clients:

      The first is Asset Advisor, a program that accommodates a broad range of investment
recommendations. The fee is set based on negotiation between the client and the advisor.

       The firm’s actual charges on Asset Advisor accounts are set at various levels usually at or
below 1.5%. The fee is set based on negotiation between the client and the advisor.

      The second non-discretionary option is Custom Choice, which provides a broad array of
open-end mutual fund options.

       The firm’s actual charges on Custom Choice accounts are set at various levels usually at
or below 1.2%. The fee is set based on negotiation between the client and the advisor.

        With respect to advisor directed (discretionary) fee based accounts, Cresap Inc. uses the
Private Investment Management (PIM) product made available by Wells Fargo. The firm’s
actual charges on PIM are set at various levels usually at or below 2%. The fee is set based on
negotiation between the client and the advisor.

               For all advisory accounts held in the aforementioned programs at our clearing
firm (Wells Fargo Clearing Services), fees are deducted at the time the account is opened
(inception) and on a quarterly basis thereafter. Inception fees are pro-rated from the time the
account is opened until the end of the calendar quarter in which it is opened. Quarterly fees
are processed within the first 15 days of each quarter.

        Fees are based on the value of assets held in the account on the last day of the quarter.
If an account was worth $400,000 on 12/31, and was subject to a 1% annual fee, the fee billed
in January would be calculated as follows:

       $400,000 (value on 12/31) X 1% = $4000 (annualized fee)

       $4000 (1/4 or one quarter) =$1000 (quarterly fee)

        Unlike regular brokerage accounts at Cresap, Inc., there are no commissions imposed on
transactions that occur within fee based advisory accounts. This applies to all securities,
including mutual funds, purchased or sold in advisory accounts. There are no custody charges
or inactivity charges. There may be exchange fees, execution fees (foreign and/or domestic)
transfer taxes when applicable, ADR custodial fees, foreign financial transaction taxes when
applicable, and any other fees required by law. With certain mutual funds or ETF’s held in an
advisory account, there may be a management fee charged by the fund or product manager.
Cresap Inc. does not receive any part of this fee.

        The vast majority of our advisory and brokerage accounts are held at Wells Fargo
Clearing Services. Client cash balances may be swept into money market shares or a bank
deposit program. Wells Fargo Clearing charges fees for the cash sweep program, and shares
a portion of these fees with Cresap, Inc. The fee may vary depending on the sweep option
chosen. Therefore, this firm derives a benefit based on the aggregate value of all brokerage and
advisory client assets in cash sweep vehicles offered by the clearing firm. The benefit may
decline or cease in an environment of very low interest rates. Because our financial advisors
receive no direct benefit from this sharing arrangement, it does not influence the advice
provided by our advisors to our clients.

        The firm entered into a clearing relationship with First Clearing (a/k/a Wells Fargo
Clearing Services) in 1990. In 2020 and 2024, the firm extended its agreement with Wells Fargo
Clearing Services and received a cash award with each extension. This award helps support our
operations, is a significant benefit to the firm, and allows us to deliver better service to our
clients. This award does not influence investment advice in any way.

        An advisor at Cresap who exercises discretion over an account may charge transaction
commissions instead of a flat fee. In these accounts, other fees normally charged in a brokerage
account may be imposed. Such fees could include fees for account transfer (charged to transfer
the account to another firm), optional exchanges, wire transfers, cash management accounts,
retirement plan accounts, delivery of U.S. Government securities, abandoned
property/dormant account, returned checks, internet account access (if applicable), fees on
foreign securities, annual inactive or maintenance fees, and postage and handling fees.
Commission rates are negotiable. Advisory accounts that pay transaction commissions instead
of fees are monitored to ensure that transaction costs do not exceed what the client would pay
in a comparable fee based account.

Item 6 Types of Clients

       The vast majority of the firms’ advisory clients are individual retail investors.

       As described earlier, investment strategies are developed by the client and advisor on
the basis of that client’s needs and objectives. There is no particular type of security,
investment strategy, or risk analysis process that is emphasized by the firm or imposed upon
advisors by the firm.

Item 7 Disciplinary Information

        There are no legal or disciplinary events that are material to a client’s evaluation of the
firm’s advisory business.

Item 8 Other Financial Industry Activities and Affiliation

        All persons that function as advisors to advisory accounts at Cresap Inc. are also
registered representatives of Cresap Inc., the broker/dealer. As registered representatives of
Cresap Inc., these individuals could recommend to clients that they open or maintain traditional
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