Financial Legacy Management Inc

Fees and Compensation
   Description
      Financial Legacy Management, Inc. bases its fees on a percentage of assets
      under management, hourly charges, and fixed fees.
       Some Retainer Agreements may be priced based on the complexity of work,
       especially when asset management is not the most significant part of the
       relationship.
       Financial plans are priced according to the degree of complexity associated
       with the client’s situation.

   Fee Billing
       Investment management fees are billed quarterly, in arrears, meaning that we
       invoice you after the three-month billing period has begun. Payment in full is
       expected upon invoice presentation. Fees are usually deducted from a
       designated client account to facilitate billing. The client must consent in
       advance to direct debiting of their investment account.
       Fees for financial plans are billed in advance, with the balance due upon
       delivery of the financial plan.

   Other Fees
       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. The
       selection of the security is more important than the nominal fee that the
       custodian charges to buy or sell the security.
       Financial Legacy Management, Inc. in its sole discretion, may waive its
       minimum fee and/or charge a lesser investment advisory fee based upon

                          Financial Legacy Management, Inc.

       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.).
       New Advisory Service Agreement fees are calculated on a formula basis and
       adjusted for complexity of individual situations. The formula is based on gross
       income, gross assets and other financial considerations.

   Expense Ratios
      Mutual funds generally charge a management fee for their services as
      investment managers. The management fee is called an expense ratio. For
      example, an expense ratio of 0.50 means that the mutual fund company
      charges 0.5% for their services. These fees are in addition to the fees paid
      by you to Financial Legacy Management, Inc.
       Performance figures quoted by mutual fund companies in various publications
       are after their fees have been deducted.

   Past Due Accounts and Termination of Agreement
       Financial Legacy Management, Inc. reserves the right to stop work on any
       account that is more than 90 days overdue. In addition, Financial Legacy
       Management, Inc. reserves the right to terminate any financial planning
       engagement where a client has willfully concealed or has refused to provide
       pertinent information about financial situations when necessary and
       appropriate, in Financial Legacy Management, Inc.’s judgment, to providing
       proper financial advice. Any unused portion of fees collected in advance will
       be refunded.

Types of Clients
   Description
      Financial Legacy Management, Inc. generally provides investment advice to
      individuals, banks or thrift institutions, investment companies, pension and
      profit sharing plans, trusts, estates, or charitable organizations, corporations
      or business entities.
       Client relationships vary in scope and length of service.

   Account Minimums
      The minimum account size is $100,000 of assets under management, which
      equates to an annual fee of $1,000.
       When an account falls below $100,000 in value, the minimum annual fee of
       $1,000 is charged.
       Financial Legacy Management, Inc. has the discretion to waive the account
       minimum. Accounts of less than $100,000 may be set up when the client and
       the advisor anticipate the client will add additional funds to the accounts
       bringing the total to $100,000 within a reasonable time. Other exceptions will
       apply to employees of Financial Legacy Management, Inc. and their relatives,
       or relatives of existing clients.
       Clients receiving ongoing asset management services will be assessed a
       $1,000 minimum annual fee. Clients with assets below the minimum account
       size may pay a higher percentage rate on their annual fees than the fees paid
       by clients with greater assets under management.

Methods of Analysis, Investment Strategies and Risk of Loss