Freedom Investment Management Inc

Item 5 – Fees and Compensation

The specific manner in which fees are charged by Freedom is established in the Freedom Investment Management
Agreement. Fees charged by Freedom to Client accounts include some or all of the following: investment
management fee, platform fee, model maintenance fee, direct investment management/administration fee, sub-
adviser or model manager fee, referral fee, and Promoter fee.

These fees are defined as follows:

Investment management fee is the charge for Freedom’s investment strategies which include proprietary and
third party models, targeted fixed income, custom account management and other strategies managed by
Freedom’s investment team.

Platform fee includes certain custodial costs, account set up, asset transfer, account administration, model
marketplace offerings and related due diligence and management, portfolio construction, Client and advisor
reporting, trading, performance calculations, billing and payments, Client and advisor online portal administration,
and, other back and middle office services. This also includes any due diligence and monitoring of specialty
products such as interval funds and group annuity/stable value funds.

Advisory Fee The Financial Advisory Firms charge Clients a separate fee (“Advisory Fee”) which is negotiated
between the Client and the Financial Advisory Firm and deducted from the Client’s Account. The Advisory Fee
will not exceed 1.5% of the Account value per annum. All Account assets, except for unaffiliated cash, will be
included by default in calculating the billable value of the Account for purposes of computing the Advisory Fee.
Clients should review their Financial Advisory Firm’s brochure and other disclosure documents for information
regarding the fees charged. The Advisory Fee is calculated as a percentage of the average daily balance of the
Client’s Account and is paid monthly in arrears. The Advisory Fee is calculated by Freedom, Freedom instructs
the Custodian to deduct the Advisory Fee from the Client’s Account, and Freedom processes the payment of the
Advisory Fee to the applicable Financial Advisory Firm.

If a client is working with a Freedom IAR, typically the Platform Fee and Advisory fee are bundled into one fee
identified in the Investment Management Agreement as Advisory Fee but displayed in the monthly Freedom
Performance Report, on the Household Fee Summary page individually as Platform Fee and Adviser Fee, together
totaling to the above-mentioned Advisory Fee.

The applicable fees described above and charged to Client accounts are described as annual fees and are
charged directly to Client accounts on a periodic basis as agreed. The fees are calculated using the average daily
balance on account values for the applicable period and charged in arrears. The fees are calculated based on the
number of calendar days in the month and are asset-flow sensitive. That is, if cash or other assets arrive or leave
the account during a period, fees are charged on those assets only for the days the assets were actually in the
account that period.

Freedom may discount its Platform Fee based on the aggregate managed dollar value in a household’s account
or accounts. The tables below illustrate the fees charged to certain Client accounts under normal circumstances.
Fees are negotiable and those negotiated fees are not illustrated below.

Freedom Platform Fee*:

  Client Household Assets at Freedom                            Annual Platform Fee

  Up to $1,000,000                                              0.16-0.45%

  $1,000,001 to $2,500,000                                      0.16-0.35%

  $2,500,001 to $5,000,000                                      0.16-0.30%

  $5,000,001 to $10,000,000                                     0.16-0.25%

  $10,000,001 and over                                          0.10% or Negotiated

Fiduciary Investment Management and Model Management for National Life’s Managed Opportunities Platform:

          Service Provided             Annualized Fee                      How billed
 Fund due diligence review and                              Charged at the plan level on all mutual
                                           0.05%
 monitoring of recommended list                             fund assets
 Model portfolio management                                 Charged to model portfolio assets in
                                           0.20%
                                                            participant accounts

Direct Investment Management/Administrative Fee:

 Annual fee: Up to 2.00%, may be discounted

Promoter and Co-Advisor Fees:

 Maximum Promoter or Co-Adviser Fee = 1.50%

Minimum account size on the Freedom platform is $25,000, which may be waived at Freedom’s discretion.

For Direct Clients (no Promoter/Co-Adviser relationship):
Direct Clients will be charged up t o 2.00% annually. Freedom reserves the right to negotiate or discount this
fee. Minimum account size is $25,000, which may be waived at Freedom’s discretion.

For Clients through a Separate Account Management Arrangement such as Schwab's Managed Account
Marketplace:
All Separate Account Management Clients will be charged an annual fee ranging from 0.25%-0.35%. Freedom
may negotiate this fee at its discretion. Minimum account size is $100,000, which may be waived at Freedom’s
discretion.

For Retirement Plan Services
Fees charged to Retirement Plan Sponsor Clients are based on the level of services provided by Freedom. 3(38)
services are provided to Plans for a fee of up to 0.40% on Plan assets annually. Freedom reserves the right to
discount this fee. DCIO services are provided for a fee of up to 0.40% on assets under management within the
Freedom managed portfolios.

For ModelxChange:
Fees charged by Freedom for services on American Trust Custody’s ModelxChange platform are typically 0.40%
...

Item 7 – Types of Clients

Freedom provides portfolio management services to individuals, high-net worth individuals, qualified retirement
plans, trusts, corporate pension and profit-sharing plans, Taft-Hartley plans, charitable institutions, foundations,
endowments, municipalities, and other U.S. businesses. Freedom offers its portfolio modeling and other services
to retirement plan sponsors through several custodians and on several record-keeping platforms.

Please refer to Item 5 for a discussion of account minimums requirements per program. Minimums per account in
the case of model licensing arrangements and third-party platform separately managed accounts are generally
determined by the third-party firm.