Fulcrum Equity Management LLC

Fees and Compensation - Item 5

 Investment Management Services
 Our firm charges an annual fee ranging up to 1.50% of assets under management for our investment management
 services depending on the investment strategies used in your portfolio. Our fee may be billed and payable either
 monthly in advance or quarterly in arrears, depending on the terms of your investment advisory agreement. In
 the case of billing in advance, the fee you are billed is based on the value of the assets on the last business day of
 the preceding calendar month. In the case of billing in arrears, the fee you are billed is based on the average daily
 balance of assets in the preceding calendar quarter. If the agreement is executed at any time other than the first
 day of a calendar month, our fees will apply on a pro rata basis, which means that the advisory fee is payable in
 proportion to the number of days in the month for which we provide management services. Our advisory fee is
 negotiable depending on individual client circumstances.

 We will deduct our fee directly from your account through the qualified custodian holding your funds and
 securities. We will deduct our advisory fee only when you have given our firm written authorization permitting
 the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement
 to you at least quarterly. These account statements will show all disbursements from your account, and you
 should review all statements for accuracy. If you have any questions about the statement(s) you receive from the
 qualified custodian, please call our main office number located on the cover page of this Disclosure Brochure.

 Either party may terminate the engagement upon 30 days written notice. You will incur a pro rata charge for
 services rendered prior to termination, which means you will incur advisory fees only in proportion to the number
 of days in the month for which you are a client. If you have pre-paid advisory fees that we have not yet earned,
 you will receive a prorated refund of those fees.

Fulcrum Equity Management, LLC
Form ADV Part 2A Brochure

 Sub-Advisory Services
 Our firm charges an annual fee ranging from 0.20% to 0.65% of assets under management for our sub-advisory
 services. Our advisory fee and payment arrangements are negotiable depending on the needs of the Primary
 Investment Adviser, which will be evidenced in a written agreement.

 The Primary Investment Adviser will deduct our fee directly from the client account through the qualified
 custodian holding the client funds and securities. Our fee will be deducted only where clients have provided such
 authorization by signing the appropriate custodial forms.

 Either party may terminate the agreement upon 30 days' written notice to the other party.

 Financial Planning and Consulting Services
 We typically offer financial planning and consulting services on either an hourly basis or a fixed fee basis. Our
 hourly fee ranges up to $250 and our fixed fees generally range up to $10,000. The hourly fee is usually billed for
 general consulting services while fixed fee arrangements are often billed for broad-based and project-based
 financial planning or for financial planning annual reviews. In limited circumstances, we may negotiate a fee above
 our maximum $10,000 fixed fee where the client requires planning services beyond the scope of our general
 financial planning services.

 Our financial planning fees - both hourly and fixed fees - are negotiable depending upon the complexity and scope
 of the service to be performed, your financial situation, and your objectives. Our hourly fees are generally due
 upon completion of services rendered. For our fixed fees, however, we require that you pay 50% of the fee in
 advance with the remaining portion due upon completion of services rendered.

 Our fee for consulting services to employee benefit plans and their fiduciaries is negotiated with the plan sponsor
 or named fiduciary on a case-by-case basis. We generally charge a fee based on the percentage of plan assets,
 which may range up to 0.75% of plan assets. Payment terms are also negotiated on a case-by-case basis. We do
 not reasonably expect to receive any other compensation, direct or indirect, for the services we provide to the
 Plan or Participants unless we are retained under a separate engagement. If we receive any other compensation
 for such services, we will (i) offset the compensation against our stated fees, and (ii) we will promptly disclose the
 amount of such compensation, the services rendered for such compensation and the payer of such compensation
 to you.

 Either party may terminate the engagement by delivering written notice to the other party. If applicable, any
 unearned fees will be refunded to the client. All terms of our engagement will be evidenced in the written
 agreement that you sign with our firm.

 Additional Fees and Expenses
 As part of our investment advisory services to you, we may invest, or recommend that you invest, in mutual funds
 and exchange traded funds. The fees that you pay to our firm for investment advisory services are separate and
 distinct from the fees and expenses charged by variable annuities, mutual funds or exchange traded funds
 (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee
 and other fund expenses. You will also incur transaction charges and/or brokerage fees when purchasing or selling
 securities. These charges and fees are typically imposed by the broker-dealer or custodian through whom your
 account transactions are executed. We do not share in any portion of the brokerage fees/transaction charges
 imposed by the broker-dealer or custodian. To fully understand the total cost you will incur, you should review all
 the fees charged by variable annuities, mutual funds, exchange traded funds, our firm, and others. For information
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Types of Clients - Item 7

 We offer investment advisory services to other registered investment advisors, registered investment advisory
 firms and individuals (including high net worth individuals).

 Generally, we impose the following account minimum requirements:

     •        Minimum account size for Equity strategies: $100,000
     •        Minimum account size for ETF strategies: $50,000
     •        Minimum account size for Mutual Fund and Advisor Directed strategies: $25,000

 We may waive or lower these minimum requirements in our sole discretion.

                   Methods of Analysis, Investment Strategies and Risk of Loss - Item 8

 Our Methods of Analysis and Investment Strategies
 We may use one or more of the following methods of analysis or investment strategies when providing
 investment advice to you:

 Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's
 financial statements, details regarding the company's product line, the experience and expertise of the company's
 management, and the outlook for the company and its industry. The resulting data is used to measure the true
 value of the company's stock compared to the current market value.

          Risk: The risk of fundamental analysis is that information obtained may be incorrect and the analysis may
          not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities
          prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable
          performance.

 Technical Analysis - involves studying past price patterns, trends, and interrelationships in the financial markets
 to assess risk-adjusted performance and predict the direction of both the overall market and specific securities.

Fulcrum Equity Management, LLC
Form ADV Part 2A Brochure

          Risk: The risk of market timing based on technical analysis is that our analysis may not accurately detect
          anomalies or predict future price movements. Current prices of securities may reflect all information
          known about the security and day-to-day changes in market prices of securities may follow random
          patterns and may not be predictable with any reliable degree of accuracy.

 Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over
 a relatively long period of time, generally greater than one year.

          Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long
          term, which may not be the case. There is also the risk that the segment of the market that you are
          invested in or perhaps just your particular investment will go down over time even if the overall financial
          markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up"
          assets that may be better utilized in the short-term in other investments.

 Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short
 period of time, generally less than one year, to take advantage of the securities' short- term price fluctuations.

          Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets
          will perform in the short-term which may be very difficult and will incur a disproportionately higher
          amount of transaction costs compared to long-term trading. There are many factors that can affect
          financial market performance in the short term (such as short-term interest rate changes, cyclical
          earnings announcements, etc.) but may have a smaller impact over longer periods of time.

 Our investment strategies and advice may vary depending upon each client's specific financial situation. As such,
 we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon,
 financial horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and
 guidelines may affect the composition of your portfolio.

 Risk of Loss
 Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee
 that our services or methods of analysis can or will predict future results, successfully identify market tops or
 bottoms, or insulate clients from losses due to market corrections or declines.
 We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance
 is in no way an indication of future performance.

 Other Risk Considerations
 When evaluating risk, financial loss may be viewed differently by each client and may depend on many different
 risks, each of which may affect the probability and magnitude of any potential losses. The following risks may not
 be all-inclusive but should be considered carefully by a prospective client before retaining our services.

          Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to high
          volatility or lack of active liquid markets. You may receive a lower price, or it may not be possible to sell
          the investment at all.

          Credit Risk: Credit risk typically applies to debt investments such as corporate, municipal, and sovereign
          fixed income or bonds. A bond issuing entity can experience a credit event that could impair or erase the
          value of an issuer's securities held by a client.

          Inflation and Interest Rate Risk: Security prices and portfolio returns will likely vary in response to
          changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and
          may reduce the purchasing power of a client's future interest payments and principal. Inflation also
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