Duvarney Craig Douglas

Fees and Compensation - Item 5

 Asset Management Services

 A. Our fees are negotiable and are not based on a share of capital gains or capital appreciation of the funds or
 any portion of the funds in your account.

 Fee Schedule

                   Account Size                Maximum Annual Fee
          $0 to $499,999                             2.00%
          $500,000 to $599,999                       1.70%
          $600,000 to $699,999                       1.42%
          $700,000 to $799,999                       1.22%
          $800,000 to $899,999                       1.07%
          $900,000 to $999,999                       0.95%
          $1,000,000 to $1,250,000                   0.85%
          $1,250,000 to $1,499,999                   0.68%
          $1,500,000 to $1,749,999                   0.57%
          $1,750,000+                                0.50%

 We offer Advisor Managed Portfolios with separate advisory fees and transaction charges. As such, in addition to
 the quarterly account fee described below for advisory services, you will also pay separate per-trade transaction
 charges.

 You will pay a quarterly account fee, in advance, based on the market value of the assets held in your account as
 of the last business day of the preceding calendar quarter. Your account fees are negotiable and will be debited
 from your account by our custodian. If you terminate your account, the account fee will be credited to you on a
 pro rata basis for the unused portion of the quarter.

 If you have more than one investment advisory account covered under the Investment Advisory Management
 Agreement at Craig DuVarney, CFP®, we will aggregate the values of your portfolios for the purposes of computing
 our management fee.

 You may make additions to the account or withdrawals from the account, provided the account continues to meet
 minimum account size requirements. Additional assets deposited into the account after it is opened will be
 charged a pro rata fee based on the number of days remaining in the then current 3-month period. Additionally,
 partial withdrawals from the account will result in a prorated portion of the fee being credited to your account.
 No fee adjustments will be made for account appreciation or depreciation.

Craig DuVarney, CFP®
Form ADV Part 2A

 B. If the account is established or closed during the middle of a quarter, you will pay a prorated portion of the
 advisory fee based on the number of days the account was under Craig DuVarney, CFP®’s management. You will
 authorize us in the Investment Advisory Management Agreement to instruct the custodian to deduct the advisory
 fee directly from your account. Pershing will provide you with a quarterly statement that lists the total fees
 deducted from the account as well as all transactions that were conducted in the account that quarter.

 C. In addition to the advisory fees above, you will pay transaction fees for securities transactions executed in your
 account in accordance with the custodian’s transaction fee schedule. You will also pay fees for custodial services,
 account maintenance fees, and other fees associated with maintaining the account. These fees are not charged
 by Craig DuVarney, CFP®, and are charged by the product, broker-dealer, or account custodian. Craig DuVarney,
 CFP®, does not share in any portion of these fees. Additionally, you will pay your proportionate share of the
 fund’s management and administrative fees and sales charges as well as the mutual fund adviser’s fee of any
 mutual fund they purchase. These advisory fees are not shared with Craig DuVarney, CFP® and are compensation
 to the fund manager. More information is available in the mutual fund prospectus.

 In addition to the per-trade transaction charges referenced above, you will also be subject to per-trade
 confirmation fees as disclosed on your trade confirmation and an additional fee for each trade confirmation that
 you do not elect to receive electronically. You will also be subject to an additional, per-trade transaction charge
 on the selling of certain securities as disclosed on your trade confirmation. These fees are not shared with us but
 are transaction charges paid to Osaic Wealth and our custodian. Please see Item 10, which explains our
 relationship with Osaic Wealth.

 There are additional fees relating to IRA and Qualified Retirement Plan accounts that you will incur such as
 maintenance and termination fees. You will find these fees disclosed in the account application paperwork
 provided to you associated with these accounts.

 D. The advisory fee is billed quarterly in advance. Fees will be based on the value of the account on the last
 business day of the preceding calendar quarter. If your account does not contain sufficient funds to pay the
 advisory fees, we have the limited authority to sell or redeem securities in sufficient amounts to pay advisory
 fees. Except for ERISA and IRA accounts, you may reimburse your account for advisory fees paid to Craig
 DuVarney, CFP®.

 Fee calculation example for a $350,000 account during 2nd quarter (April, May, and June):

     ➢    $350,000 x 2.00% =$7,000 divided by 365 x 91 = $1,745.21 Quarterly Fee

 Craig DuVarney, CFP®, may change the above fee schedule upon a 30-day prior written notice to you.

 E. As previously indicated, Craig DuVarney is separately Registered Representative of Osaic Wealth, a registered
 Broker-Dealer, member of the Financial Regulatory Association (FINRA) and SIPC. Craig DuVarney, as a Registered
 Representative, may receive trail commissions (i.e., 12b-1 fees) for a period of time as a result of directing
 securities transactions through Osaic Wealth. Load and no-load mutual funds pay annual distribution charges,
 sometimes referred to as 12b-1 fees. 12b-1 fees come from fund assets, therefore, indirectly from your assets.
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Types of Clients - Item 7

 Craig DuVarney, CFP®’s services are focused primarily toward high-net-worth individuals and families. Exceptions
 will be made at Craig’s discretion on a case-by-case basis.

Craig DuVarney, CFP®
Form ADV Part 2A

 The minimum investment required under our Asset Management Program is generally $1,000,000 for Advisor
 Managed Portfolios accounts. Accounts below this minimum may be accepted on an individual basis at our
 discretion. Such circumstances may include, but not be limited to, those situations where additional assets will
 soon be deposited, or where the client has other commission-based assets with Craig DuVarney. Existing clients
 are required to maintain a minimum of $1,000,000 in assets under management with us. In our sole discretion,
 we may waive this requirement. The minimum requirement is based upon the aggregate value of investment
 advisory accounts in the household. You should be aware that performance may suffer due to difficulties with
 diversifying smaller accounts and that a lack of diversification can lead to greater portfolio risk. Performance of
 smaller accounts may vary from the performance of accounts with more dollars invested because fluctuations in
 the market may affect smaller accounts more.

                    Methods of Analysis, Investment Strategies and Risk of Loss - Item 8

 A. Craig DuVarney, CFP®, conducts economic analysis and attempts to analyze and determine economic trends.
 Additionally, Craig DuVarney, CFP®, conducts fundamental analysis. Fundamental analysis generally involves
 assessing a company’s or security’s value based on factors such as sales, assets, markets, management, products
 and services, earnings, and financial structure.

 B. Investing in securities involves risk of loss, including the potential loss of the principal money you are investing.
 Therefore, your participation in the management program offered by Craig DuVarney, CFP®, requires you to be
 prepared to bear the risk of loss as well as the fluctuating performance of your accounts. Market values of
 investments will always fluctuate based on market conditions.

 We do not represent, warrantee, or imply that the services or methods of analysis we use can or will predict
 future results, successfully identify market tops or bottoms, or insulate you from losses due to major market
 corrections or crashes. Past performance is no indication of future performance. No guarantees can be offered
 that your goals or objectives will be achieved. Further, no promises or assumptions can be made that the advisory
 services offered by Craig DuVarney, CFP®, will provide a better return than other investment strategies.

 The primary risk factors applicable to our investment program generally include:

     •    Market risk – The price of a security, bond, mutual fund and/or exchange-traded fund may drop in
          reaction to tangible and intangible events and conditions. This type of risk is caused by external factors
          independent of a security's particular circumstances. For example, economic, political and social
          conditions may trigger market-related events.
     •    Interest rate risk – The chance that investment prices will change based on a move in interest rates (bond
          prices decline as interest rates rise). Relative to fixed income securities with near-term maturities, longer
          maturity bonds will have a larger change in price with a move in interest rates.
     •    Inflation risk – The risk that investment returns will be below the general increase in prices due to
          inflation.
     •    Category or style risk – The chance that one investment category or style may underperform or
          outperform other categories and styles.
     •    Credit risk – The chance that a bond issuer will fail to pay interest and principal in a timely manner.
     •    Reinvestment risk – The potential exposure that future proceeds from investments may have to be
          reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income
          securities.
     •    Early redemption risk – Some bonds have features that allow the bond issuer to repurchase or redeem
          the bond before maturity at a specific price. This risk is the chance that the borrower will do so; thus,
          expose the investor to a lower-than-expected return on that bond investment.

Craig DuVarney, CFP®
Form ADV Part 2A

     •   Systematic risk – Also known as "market risk," this is the chance of a severe drop of an entire financial
         market (e.g., political or social upheaval, natural disaster, etc.).
     •   Unsystematic risk – Also known as "specific risk," this is the chance of a decline in the value of a particular
         asset (i.e., an individual stock declines while the overall stock market is not impacted).
     •   Currency risk – Also known as "exchange rate risk," this is the chance that foreign investments will be
         subject to fluctuations in the value of the dollar against the currency of the investment's country of origin.
     •   Tax risk – This is the chance that the taxing authority changes its tax rates or policies (e.g., rescind tax-
         exempt status of particular bonds).
     •   Liquidity risk – This is the risk whereby the ability to buy or sell a security becomes more difficult and,
         therefore, negatively impacts the price at which one is able to transact in the security.
     •   Financial risk – Excessive borrowing to finance the ongoing operations of a business increases the risk of
         profitability, because the company must meet the terms of its obligations in good times and bad. During
         periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or declining
         market value.
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