D & P Investment Advisors Ltd

Item 5. Fees and Compensation

         D & P offers its services on a fee basis, which may include hourly and/or fixed fees, as well as fees based
         upon assets under management.

         Financial Planning and Consulting Fees

         D & P charges an hourly fee for financial planning and consulting services. These fees are negotiable,
         but generally range from $270 to $300 on an hourly rate basis, depending upon the level and scope of the
         services and the professional rendering the financial planning and/or the consulting services. If the client
         engages D & P for additional investment advisory services, D & P may offset all or a portion of its fees for
         those services based upon the amount paid for the financial planning and/or consulting services.

         Prior to engaging D & P to provide financial planning and/or consulting services, the client is required to
         enter into a written agreement with D & P setting forth the terms and conditions of the engagement.
         Generally, D & P requires one-half of the financial planning / consulting fee (estimated hourly) payable
         upon entering the written agreement. The balance is generally due upon delivery of the financial plan or
         completion of the agreed upon services.

Page 5                                                                                                          © MarketCounsel 2026

         D & P Investment Advisors, Ltd Disclosure Brochure

         Investment Management Fee

         D & P provides investment management services for an annual fee of 1.00% of the market value of the
         assets being managed by the firm. D & P’s annual fee is prorated and charged quarterly, in arrears,
         based upon the market value of the assets being managed by D & P on the last day of the previous
         quarter. Effective April 1, 2023, D & P does not charge its advisory fee on money market balances
         greater than $10,000 per account per client on accounts that are charged an asset-based fee. Prior to
         this, it disclosed balances greater than $1,000. D & P, in its sole discretion, may negotiate to charge a
         lesser management fee based upon certain criteria (i.e., anticipated future earning capacity, anticipated
         future additional assets, dollar amount of assets to be managed, related accounts, account composition,
         pre-existing client, account retention, pro bono activities, etc.). In addition, in limited circumstances, D & P
         may charge an annual fixed fee (up to $20,000) in lieu of an asset-based fee. This fixed fee will be
         prorated and charged quarterly in arrears.

         D & P’s investment management fee is exclusive of, and in addition to brokerage commissions,
         transaction fees, and other related costs and expenses which are incurred by the client. D & P does not,
         however, receive any portion of these commissions, fees, and costs.

         Additional Fees and Expenses

         In addition to the advisory fees paid to D & P, clients may also incur certain charges imposed by other
         third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions
         (collectively “Financial Institutions”).   These additional charges may include securities brokerage
         commissions, transaction fees, custodial fees, charges imposed directly by a mutual fund or ETF in a
         client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund
         expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund
         fees, and other fees and taxes on brokerage accounts and securities transactions.

         Clients may grant D & P the authority to directly debit their accounts for payment of the D & P’s
         investment advisory fees. The Financial Institutions that act as qualified custodian for client accounts
         have agreed to send statements to clients not less than quarterly detailing all account transactions,
         including any amounts paid to D & P.

         Fees for Management During Partial Quarters of Service

         For the initial period of investment management services, the fees are calculated on a pro rata basis.

         The Agreement between D & P and the client will continue in effect until terminated by either party
         pursuant to the terms of the Agreement. D & P’s fees are prorated through the date of termination and
         any remaining balance is charged or refunded to the client, as appropriate.

         If assets are deposited into or withdrawn from an account after the inception of a billing period, the fee
         payable with respect to such assets is not adjusted to reflect the interim change in portfolio value. Clients

Page 6                                                                                                             © MarketCounsel 2026

         D & P Investment Advisors, Ltd Disclosure Brochure

         may make additions to and withdrawals from their account at any time, subject to D & P’s right to
         terminate an account. Additions may be in cash or securities provided that D & P reserves the right to
         liquidate any transferred securities or decline to accept particular securities into a client’s account.
         Clients may withdraw account assets on notice to D & P, subject to the usual and customary securities
         settlement procedures.     However, D & P designs its portfolios as long-term investments and the
         withdrawal of assets may impair the achievement of a client’s investment objectives. D & P may consult
         with its clients about the options and ramifications of transferring securities. However, clients are advised
...

Item 7. Types of Clients

         D & P provides its services to individuals, pension and profit-sharing plans, trusts, estates, charitable
         organizations, corporations and business entities.

         Minimum Account Requirements

         D & P does not impose a stated minimum fee or minimum portfolio value for starting and maintaining an
         investment management relationship.

Page 9                                                                                                       © MarketCounsel 2026

          D & P Investment Advisors, Ltd Disclosure Brochure