Girard Advisory Services LLC

FEES AND COMPENSATION
Investment Advisory Fees:
Advisor’s fees for investment advisory services are generally charged based on a percentage of
assets under management. Fees are payable when services are rendered. Fees are calculated based
on 1.00% on the first $2,000,000.00, 0.75% on the next $3,000,000.00 and 0.50% on assets
exceeding $5,000,000.00. Fees can be negotiated based on special circumstances. For example,
fees may differ from those stated herein because of pre-existing or long-standing relationships,
anticipated client additions to assets under management, changing market conditions or other
reasons.

Fees are billed and collected quarterly, either in advance or in arrears, based on the terms of the
Advisory Agreement entered into between Advisor and the client. Fees are calculated based on the
closing market value of the account, including cash and cash equivalents, on the last day of the
previous calendar quarter. Fees may be deducted from a client’s account(s) directly with prior
authorization and direction from the client. In the event an account is closed or the advisory
agreement is terminated, and the Advisor has received unearned fees, the Advisor will prorate
such fees as of the date of termination and promptly refund any unearned portion to the client. The
calculation of the client's final bill is centralized and is part of the account closing process. Clients
are provided with quarterly statements reflecting performance, holdings, and the Advisory fee to
be deducted.

Financial Planning Fees:
Advisor charges a fee for financial planning and consulting services. Advisor’s fee starts at
$5,000.00 and can exceed this amount, as agreed upon between Advisor and client, depending on
the scope and complexity of the services to be provided. The fee Advisor will charge a client is
disclosed in a Financial Planning Services Agreement entered into between the Advisor and client.

One-half of the agreed upon fee is due immediately upon acceptance by the client. The remaining
one-half of the fee is due at completion and delivery of the written financial plan. Advisor will not
charge an upfront fee exceeding $1,200.00 that is more than six (6) months in advance of financial
planning services being delivered. If financial planning services cannot be delivered within that
timeframe, Advisor will return to client any amount exceeding $1,200.00 and will instead collect
any fees due in excess of this amount upon delivery of the financial plan. A client may elect to
have Advisor deduct this fee from an account they maintain with Advisor if such is the case.

Financial planning services cease upon delivery of a financial plan to a client unless the client
elects to engage Advisor for ongoing financial planning services at a timeframe and amount
agreed upon between Advisor and client as disclosed in a Financial Planning Services Agreement.
In the event the agreement is terminated by either party prior to completion of the financial plan,

and Advisor has received unearned fees, the Advisor will prorate such fees as of the date of
termination and promptly refund any unearned portion to the client.

Upon a client’s request, Girard may recommend the services of other professionals for
implementation of recommendations made by Advisor pursuant to a financial plan (i.e. attorneys,
accountants, brokers, insurance agents, etc.), including representatives of Advisor in their separate
registered/licensed capacities as registered representatives and insurance agents of Girard
Investment Services, LLC (“GIS”), a FINRA member broker-dealer, a licensed insurance agency
and affiliated firm. Please refer to the section below entitled “Other Financial Industry Affiliations
and Activities” for additional information and important disclosures related to the conflicts of
interest this can present.

Clients are under no obligation to engage the services of any recommended professional by
Advisor, either affiliated or unaffiliated, and may implement financial planning recommendations
made by Advisor through the professionals of their choice. The client retains sole discretion over
all implementation decisions and is free to accept or reject any or all recommendations from the
Advisor and/or its representatives.

Retirement Plan Investment Advice and Consulting Fees:
Advisor charges a fee for providing investment advisory and consulting services to Retirement
Plan Sponsors. The fee for Advisor’s services are as follows:
.75% on plan assets of $1 to $1,000,000
.50% on plan assets of $1,000,001 to $2,000,000
.35% on plan assets of $2,000,001 to $5,000,000
.25% on plan assets of $5,000,001 to $10,000,000
.10% on plan assets of $10,000,001 to $20,000,000
.05% on plan assets of $20,000,001 and above

Advisor has a minimum annual fee of $2,500.00. This fee will begin accruing with the contract
start date. If the plan fees collected in a quarter are less than $625.00, the difference will be billed
to the Plan Sponsor. Advisor’s fee is negotiable and the agreed upon fee is disclosed to the Plan
Sponsor in an Investment Advisory Services Agreement entered into between Advisor and the
Plan sponsor.

Advisor’s fee is calculated quarterly based on the market value of the plan’s assets (excluding
self-directed brokerage assets) on the last business day of the previous quarterly fee period
(without adjustment for anticipated withdrawals by Plan participants or other anticipated or
scheduled transfers or distributions of assets) as reported by the Custodian or Record Keeper.

Advisor’s fee is paid to Advisor by the Custodian of plan assets as authorized by the Plan
Sponsor. The Custodian is responsible for providing a quarterly statement to the Plan Sponsor
indicating all amounts disbursed from the plan, including the amount of fees paid to Advisor. Plan
Sponsor is responsible for ensuring that such statement is provided by the Custodian.
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TYPES OF CLIENTS
Girard provides investment advice to individuals, pension and profit-sharing plans, trusts, estates,
charitable organizations and business entities. The Company currently has a minimum investment
requirement of $350,000.00 for wealth management clients but may waive this based on
circumstances such as planned additions or if services are provided through Advisor’s mutual
fund and/or exchanged traded fund only investment management solution. The minimum account
size for this solution is $50,000.00.

METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF
LOSS
Girard’s investment philosophy is based on principles of asset allocation, diversification, and
tailoring investments to a client’s objectives and circumstances. Investments may include
domestic and foreign equities, exchange-listed or over-the-counter securities, options, exchange
traded funds, real estate investment trusts, mutual funds, fixed income securities such as U.S.
Treasuries, agencies, mortgage-backed securities, corporate debt, municipal debt, and certificates
of deposit, and separately managed accounts by independent advisors that include tax-managed
direct indexing and long/short strategies, and options overlay strategies.

Girard utilizes a proprietary research process to select stocks, bonds, exchange traded funds, and
mutual funds. With respect to equity research, we follow and maintain a list of approximately 100
large cap stocks and base our research on the fundamentals of each company and use our system
to ascertain fair value for each holding. Girard also utilizes outside third party research to help
with investment analysis. The approved list of securities is maintained by the Investment
Committee, which is charged with the function of determining which investments are added and
subtracted from the approved list. The Investment Committee reviews the securities on the firm’s
approved list on a regular basis and is headed by the Chief Investment Officer and typically has
between seven to ten members on the committee. Voting members of the Investment Committee
are entitled to vote on matters requiring Investment Committee approval. One or more members
of the Investment Committee chair sub committees, which include the Equity Sub Committee and
the Manager Sub Committee. Each Sub Committee Chair provides updates on research occurring
in the sub-committee and makes recommendation to the Investment Committee.

Risks: There are a number of risks associated with the investment strategies offered by the
Advisor, including, but not limited to, the following:

Stock Risks: Portfolios managed by the Advisor are subject to stock market risk, which is the
chance that stock prices overall will decline. Stock markets tend to move in cycles, with periods of
rising prices and falling prices. Such risk will vary based on the percentage of stocks owned in a
given strategy and client portfolio.

Bond Risks: Bonds are subject to interest rate risk, which is the chance that bond prices overall
will decline because of rising interest rates. Interest rate risk will vary based on the percentage of
bonds owned in a given strategy. In addition, long-term bonds have a higher interest rate risk and
are much more sensitive to interest rate changes than are the prices of short-term bonds. Bonds are
also subject to credit risk, the chance that a bond issuer will fail to pay interest and principal in a
timely manner or, that negative perceptions of the issuer’s ability to make such payments will
cause the price of that bond to decline. Finally, some bonds may be subject to call risk. This is the
chance that in a declining interest rate environment the issuer of a bond will repay or call
securities with higher coupons before their maturity dates.

Asset Class Risks: Investments in specific asset classes entail different investment risks. For
example, small cap stocks (stocks with a market capitalization of 2 billion or less) tend to be more
volatile than large or mid-cap stocks. International and emerging market stocks include risks due
to currency fluctuations, foreign taxes, political instability, different financial accounting
standards and possibility of illiquid markets. Real estate investing includes risks such as declines
in the value of real estate, changing economic conditions, and changes in tax laws or property
taxes.

Tax-Managed Long/Short Strategy Risks: Tax-managed long/short strategies, including
strategies managed by Aperio, may use short sales, margin, borrowing, and leverage. These
strategies may create opportunities for tax-loss harvesting, diversification, or portfolio transition,
but tax benefits are not guaranteed and depend on a client’s tax circumstances, realized gains and
losses, fees, borrowing costs, wash-sale rules, market conditions, and future tax law. Short-sale
losses can be substantial and, in theory, unlimited. Margin use can magnify losses, and a custodian
may require additional collateral or liquidate assets without prior notice. These strategies are
generally intended for taxable, non-ERISA clients who can understand and bear the additional
risks, costs, and complexity.

Independent Advisor Conflict and Oversight Risks: The use of Independent Advisors
introduces additional conflicts and oversight considerations. Girard receives its advisory fee while
the Independent Advisor receives a separate fee, which creates an incentive to recommend a
program that increases the client’s total cost. Independent Advisors, their affiliates, custodians, or
other service providers may also receive economic benefits from advisory fees, margin interest,
securities lending, stock-borrow arrangements, affiliated products, or transaction activity. Girard
seeks to address these conflicts through disclosure, due diligence, client-specific suitability
review, and ongoing monitoring, but these conflicts cannot be eliminated in every case.
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