Elevated Capital Advisors LLC

Item 5 – Fees and Compensation

Clients who engage ECA to provide discretionary and/or non-discretionary investment advisory services
will incur advisory fees, inclusive of all sub-advisory and/or solicitor fees, that may not exceed 2.25% of
the total assets placed under ECA’s direct management. The fee amount will depend on the Financial
Advisor and program chosen and all advisory fees will be provided in writing before signing an Investment
Advisory Agreement.

In our Managed Model Portfolios, ECA utilizes an independent third-party turnkey asset management
platform (“TAMP”) to provide model portfolio management, trading, and rebalancing services. ECA
currently utilizes AE Wealth Management, LLC (“AE Wealth”), an independent, non-affiliated registered
investment adviser, as a TAMP for managed client accounts.

ECA provides Retirement Plan Services to retirement plan sponsors. Fees for retirement plan services
provided to ERISA plan sponsors may not exceed 1.25%. A Plan Sponsors agreement with the
recordkeeper will determine the frequency at which fees are paid. If you are a Plan Sponsor and have
questions about your recordkeeper’s pay schedule, please confer with your IAR or refer to your
agreement with the recordkeeper.

Clients participating in Howard Capital strategies via a SDBA pay advisory fees to Howard Capital plus
the internal operating expenses of the underlying funds, that may total up to 2.75%. ECA and its financial
advisers receive a portion of the advisory fee paid to Howard Capital for introducing clients. This creates
a conflict of interest, which ECA mitigates by recommending the program only when appropriate for the
client.

TPFG fees for existing legacy accounts are paid from the fund expenses and described in the applicable
fund prospectus.

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Managed Model Portfolios

         Annual ECA Administration Fee*                           Annual Financial Advisor Fee
                  0.25 - 0.75%                                            0.00- 1.25%

*The ECA administration fee a client pays will be disclosed in detail on the Investment Advisory
Agreement. The fee varies based on the amount of AUM being managed and other factors and will not go
above 0.75%.

For Managed Model Portfolios that utilize AE Wealth as a TAMP, AE Wealth’s compensation for its
investment management services is included within the annual ECA Administration fee and is not
charged separately or in addition to the fees disclosed above.

Fees charged for our Managed Model Portfolios are negotiable based on the investment adviser
representative providing the services, the type of client, the complexity of the client's situation, the
composition of the client's account (i.e., equities versus mutual funds), the potential for additional account
deposits, the relationship of the client with the investment adviser representative, and the total amount of
assets under management for the client.

Clients participating in TAMP-managed accounts do not pay a separate advisory fee directly to AE
Wealth. Additional information regarding AE Wealth’s services and fees is available in AE Wealth’s Form
ADV Part 2A, which is provided to clients.

Advisor Directed Managed Accounts

         Annual ECA Administration Fee                            Annual Financial Advisor Fee
                    0.25%                                                 0.00 – 1.75%

Fees charged for our Advisor Directed Account Services are negotiable based on the investment adviser
representative providing the services, the type of client, the complexity of the client's situation, the
composition of the client's account (i.e., equities versus mutual funds), the potential for additional account
deposits, the relationship of the client with the investment adviser representative, and the total amount of
assets under management for the client.

Self-Directed Brokerage Account (“SDBA”)

                  Management Fee*                                       Administrative Fees
                      1.25%                                                  0.47%**

*Howard Capital will pay ECA 0.75% of the management fee shown above. ECA then pays the clients’
financial advisor 0.50% with the remaining 0.25% staying with ECA for administration services. Clients
investing in a Portfolio do not directly pay any fees as all fees are paid from within the funds (from the
“internal fund fees”) which are reflected in the Funds’ NAV.
**Fees within this category are broken out between “Other Expenses” and “Acquired Fund Fees and
Expenses”. These are the indirect costs of investing in other investment companies.
In addition, the funds pay various custodial and brokerage platforms for Fund distribution and marketing
(“Rule 12b-1 fees”). ECA nor its advisers receive any portion of the 12b-1 fees. This fee is generally
around 1.00% making the total annual fund operating expenses a client pays 2.72%. Investors should

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review the Funds’ prospectus and Howard Captial’s Form ADV for additional information about Howard
Capital funds, services and fees.

Payment of Fees for Managed Accounts

Except for SDBA accounts, fees are directly withdrawn from a client’s account on a quarterly basis. Fees
are charged based on a percentage of assets under management, billed in advance (at the start of the
billing period) on a quarterly calendar basis and calculated based on the fair market value of your account
as of the last business day of the current billing period. Fees are prorated (based on the number of days
service is provided during the initial billing period) for your account opened at any time other than the
beginning of the billing period. If asset management services commenced in the middle of the billing
...

Item 7 – Types of Clients

ECA provides investment advisory services to the following types of clients through Financial Advisors
registered with ECA:

    •   Individuals
    •   High net worth individuals
    •   Trusts, Estates, or Charitable Organizations
    •   Retirement and profit-sharing plans
    •   Corporations or other businesses entities

Minimum Investment Amounts Required

ECA typically requires a minimum of $10,000 to open an account. Exceptions may be granted to this
minimum if approved by both your IAR and ECA.

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