Flack Ember Louise

Fees   and Compensation

Adviser is compensated for Advisory Services by fees, and not by commissions arising from the sale of
investment products. Fees are not negotiable, and are applied uniformly to all Clients. Fees for financial
planning consultation and analyses depend on the complexity of a Client’s situation and scope of services
provided. Fixed fees for Financial Plan analyses and Financial Plan Updates range from $950 to $10,000,
plus any out-of-the-ordinary reimbursable expenses (such as travel costs, fees for professional advisers
such as attorneys or CPAs, etc.). Fixed fees shall be paid by check upon execution of the Client Advisory
Agreement, but are never required to be paid six months or more advance. When Adviser is engaged on
a fixed fee arrangement, Clients may expect that all consultations reasonably related to development of
the Financial Plan and Financial Plan Update will be included in the scope of work. On the other hand, an
hourly fee of $350 per hour, plus reimbursable expenses, may be agreed upon for special situations
involving highly complex estates or financial issues requiring advanced calculations. Hourly fees shall be
invoiced monthly in arrears, offset by any deposit paid to Adviser upon execution of the Client Advisory
Agreement. Hourly fees may be in addition to, or in lieu of fixed fees, as agreed upon by the Adviser and
Client.

The Adviser or Client may terminate the Client Advisory Agreement at any time by providing written notice
to the other party. If at the point of termination, Adviser has not delivered the Financial Plan or Financial
Plan Update report to the Client, a portion of the fee paid upon execution of the Client Advisory
Agreement shall be refunded to the Client within thirty (30) days of termination notice. Such refund shall
be calculated as the resulting difference between the fee(s) paid to date, minus an hourly rate of three
hundred fifty dollars ($350) times the number of hours, full and fractional, the Adviser has invested in the
case analysis and consultation during the period beginning with data gathering and ending upon Adviser’s
receipt of termination notice.

Investment management fees are based on the volume of assets under Adviser’s management. Adviser
does not provide any brokerage services, and does not receive any compensation relating to managing a
Client’s investments other than its investment management fees. Investment management fees are
calculated based on the asset value of the Client’s account at the end of each quarter-year and are paid
quarterly in arrears. Investment management annual fees are as follows: 1.40% for an account size up to
$250,000, 1.05% for the next $250,000, .70% for the next $500,000, .60% for the next $1 million, and .50%
for that portion of an account over $2 million. Investment management fees are not negotiable. Clients
pay investment management fees to Adviser. By separate agreement between the Client and custodian,
Clients authorize custodian to deduct Adviser’s investment management fees from the Client’s account(s)
and to remit the same to Adviser. Client’ custodian shall provide written notice no later than the time of
the fee deduction, detailing the amount of the fee, method of calculation and amount of assets upon
which the fee is based. The Adviser or Client may terminate the Investment Management Agreement at
any time by providing written notice to the other party. Adviser’s final investment management fee will
be calculated on a pro-rata basis based on the number of days the account was under Adviser’s
management responsibility during the final quarter-year of the engagement. Additionally, each mutual
fund in a Client’s account pays its own advisory fees and other expenses which are set forth in each mutual
fund's prospectus. The mutual fund fees and expenses are separate charges from Adviser’s investment
management fees and are paid to the mutual fund, and not to Adviser. Mutual fund fees are established
by the fund's Board of Directors and are subject to change from time to time. There may also be custody
fees or other charges imposed by the custodian for certain transactions.

Ember L. Flack, JD, CFP®, CLU, ChFC
Brochure/March 2026

      Performance               - Based Fees and Side            - By - Side Management

Adviser does not charge performance-based fees.

                                         Types of       Client     s

Ms. Flack’s impressive credentials and depth of experience attract a broad range of Clients, representing
nearly 40 households throughout the United States, and more than $175 million of assets under
management as of December 31, 2024. Her practice is well suited to serving high-net worth, individual
Clients. Individuals or couples with a net worth of at least $500,000 are positioned well to capture the
best value from Ms. Flack’s services and skills. However, Ms. Flack does not define a fixed minimum net
worth to consider an engagement, and establishes investment accounts as small as $250,000.

Her Clients range in age from early 40s through early 90s, with a full complement of goals, needs, and
limitations. Clients who are still in the workforce are often well-along in their careers, having already
progressed with basic financial accomplishments that focus on accumulation and managing financial risk.
These middle-aged Clients engage Ms. Flack to identify specific action steps to propel their financial
success to the next level, typically focusing on retirement and education funding, investment strategy,
and managing the risk of premature death, disability, and long term care expense. Additionally, a
significant portion of Ms. Flack’s Clientele is retired, enjoying the distribution phase of the investment
cycle. These older Clients seek to manage their investment estate wisely, understand appropriate
withdrawal boundaries, and to manage more complex risks of retirement. Planning for the successful
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