Financial Counselors Inc

Fees and Compensation
         Description
          FCI Advisors bases its fees on a percentage of assets under management. Fees are negotiable.
          We may charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship,
          type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of
          assets to be managed, related accounts, account composition, negotiations with clients, etc.).
          Fees, minimum fees, and minimum account sizes are negotiable and may be waived under certain
          circumstances.

         Advisory Fees
          Fixed Income Accounts below $10 Million
          .40 of 1% on the first $5,000,000 of portfolio market value
          .30 of 1% on the balance of the portfolio market value

          Institutional Fixed Income Accounts ($10 Million Minimum)
          .30 of 1% on the first $25,000,000 of portfolio market value
          .25 of 1% on the next $25,000,000 of portfolio market value
          .20 of 1% on the balance of portfolio market value
          Model Portfolio

          FCI provides a model portfolio or buy/sell lists for certain clients at a fee of 0.20% to 0.25% of all assets
          under management under the model. FCI considers assets under our model delivery to be assets under
          advisement. These fees may be negotiated.

         Fee Billing
          We allow clients to elect whether they would like us to invoice our advisory fees directly to them or if they
          would like to direct their custodians to calculate and pay our fees. Most of our fees are handled quarterly in
          advance or arrears. Other arrangements may be negotiated with clients.

         Other Fees
          FCI is not a custodian so our clients will arrange payment of custodian fees with the custodian of their
          choice. Other fees our clients pay include expense ratios associated with mutual funds or exchange traded
          funds. There are typically also fees related to trading securities such as brokerage commissions (see more
          information in “Brokerage Practices” on page 16) and transaction fees incurred by other handlers of the
          trades. Custodians may charge transaction fees on purchases or sales of certain mutual funds and
          exchange-traded funds. These transaction charges are usually small and incidental to the purchase or sale
          of a security. We believe the selection of the security is more important than the nominal fee the custodian
          charges to buy or sell the security.
          FCI serves as financial advisor for a mutual fund and several Collective Investment Trusts (CITs). If a fund
          for which we serve as advisor is deemed an appropriate investment for a client of our discretionary service,
          we will waive our advisory fee for the portion of the account invested in those funds or a CIT share class
          selection with no advisory fee may be used instead.
         Refunds of Advisory Fees Paid in Advance
          If an advisory relationship begins after the first day of a fee period or terminates before the last day of a fee
          owed, fees are prorated accordingly. Any unearned fees which have been prepaid at the date of
          termination will be refunded.

         Compensation for Sale of Securities
          We do not receive compensation from the sale of securities. Some of our affiliates receive shareholder
          servicing fees associated with their shareholder servicing activities.

Types of Clients
         Description
          FCI Advisors provides investment advisory services to individuals, investment companies, pension and
          profit sharing plans charitable organizations, corporations, and other business entities.
          We also provide investment management services to clients using Model Portfolios of one or more of our
          investment strategies. The models will be providedto trust companies, other investment advisors or other

          institutional clients for use in management of assets. For these accounts we may not be responsible for
          trade execution, timing of trade placement, brokerage selection, negotiation of commissions, or other fees
          paid by investors. We will update the model when changes are made to the investment strategies. It is up
          to the model platform client how these updates are executed across its client base.

         Account Minimums
          The recommended minimum account size is:
          Separate Accounts: $250,000
          Wrap Accounts:
                      FCI-UBS ADVISOR ALLOCATION PROGRAM Portfolios: $100,000
                      FCI-UBS ACCESS Portfolios: $100,000
                      FCI-UBS Strategic Wealth Portfolios: $100,000
                      FCI-UBS MAC Portfolios: $250,000

          We have the discretion to waive account minimums. Accounts valued below the minimums noted above,
          and for other strategies, are most often set up when the client and the advisor anticipate the client will add
          additional funds to the accounts. Other exceptions will apply to employees (and employees’ relatives) of
          FCI and of our affiliates.
          UBS bills the client directly for FCI's management fees in accordance with fee schedules that are generally
          the same as those for separate accounts. As with separately managed accounts, fees and minimums for
          MAC accounts are negotiable. Additional information concerning wrap fees, commissions, UBS AAP,
          ACCESS and MAC programs are provided in the UBS Wrap Fee and Alternative Program Disclosure
          Brochure ("UBS Wrap Fee Disclosure Brochure").

    Methods of Analysis, Investment Strategies and Risk of Loss
         Methods of Analysis and Investment Strategies
          Security analysis methods often include charting, fundamental analysis, technical analysis, and macro
          analysis.
          The main sources of information include financial newspapers and magazines, inspections of corporate
          activities, research materials prepared by others, corporate rating services, timing services, annual reports,
          prospectuses, filings with the Securities and Exchange Commission, and company press releases.
          Other sources of information include Morningstar mutual fund information, Morningstar stock information,
          Fact Set, street research, Bloomberg and internet research.

          Some of FCI’s Investment Professionals use artificial intelligence (AI) applications to support writing efforts,
          to test accuracy and comprehensiveness of written works. Others use AI to summarize and identify
          statistics in research and prospectus reports. We will continue to evaluate how AI may help us support our
          client services and investment research. We do not use AI for investment recommendations.

          FCI Fixed Income Core and Intermediate Strategies
          Investment Objective
          FCI’s Core, Government Credit, Aggregate, and Intermediate fixed income investment strategies seek to
          deliver superior returns relative to an appropriate Benchmark over a market cycle, while limiting the risk
          incurred by maintaining a high credit profile. We strive to consistently move the portfolio in the direction of
          best opportunities while reducing the potential of a significantly negative credit event.

        Investment Strategy
        FCI’s Core, Government Credit, Aggregate, and Intermediate fixed income investment strategies involve
        employing a time-tested, disciplined investment process which combines multiple stages of active
        management, each of which considers aspects of fundamental, behavioral, and technical analysis.
        Duration management is utilized to position the portfolio to deliver the highest return potential according to
        the outlook for interest rates and term-structure as determined by the firm’s Fixed Income Investment
        Committee. Overall duration risk is limited to a 20% deviation relative to the identified benchmark. With
        regard to sectors within the high-grade universe, allocations are incrementally emphasized or reduced
        based on the Committee’s assessment of return potential and the risk inherent in each. After careful
        analysis is performed to determine credit worthiness and relative valuation opportunities, individual issues
        are then selected to construct portfolios.
        Employing fundamental, behavioral, and technical analysis along all stages of our investment process
        allows the firm’s managers to have a forward-looking, three dimensional approach to the construction of
        client portfolios.

        FCI Intermediate Investment Grade Credit Strategy
        Investment Objective
        FCI’s Intermediate Investment Grade Credit strategy seeks to deliver superior returns relative to the ICE
        BofA 1-10 Year AAA-A US Corporate Index over a market cycle, while limiting the risk incurred by
        maintaining a high credit profile. We strive to consistently move the portfolio in the direction of best
        opportunities while reducing the potential of a significantly negative credit event.

        Investment Strategy
        The FCI Intermediate Investment Grade Creditstrategy is designed to efficiently provide investors exposure
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