GR Financial Group LLC

Item 5        Fees and Compensation
Individual Portfolio Management

Asset Based Advisory Fees
With the exception of client assets invested in our Alpha Advantage strategy, our advisory fee for
providing Individual Portfolio Management services is based upon a percentage of each client’s assets
under management, which will be deducted directly from the client’s account(s) in accordance with the
following tiered fee schedule:

                       Client AUM                                       Annual Advisory Fees

GR Financial bills its Advisory Fee monthly in advance. When calculating the Advisory Fee, GR Financial
will aggregate all investment management accounts managed by the Firm, which belong to certain familial
relations of each client. This typically is referred to as “householding”. For purposes of calculating assets
under management only, the value of a client’s account(s) will be aggregated with the account values of the
client’s spouse or partner and minor children (collectively, a “household”), which could make such accounts
eligible for a lower annual Advisory Fee (i.e., a breakpoint). Clients are required to notify GR Financial of
any such “household” relationships. Under this tiered fee billing, in the event that a client’s assets fall within
a new tier (which may result in a higher or lower fee), the client will be billed in accordance with that new
tier, which will be reflected in the client’s monthly statement. On a periodic basis, GR Financial will review
any account that has triggered an increase in a client’s Advisory Fee based on decreased asset size and
determine what caused asset levels to fall. Dependent upon the rationale, GR Financial can elect, in its sole
discretion, not to raise a client’s Advisory Fee. No less than annually, GR Financial will review each client’s
Advisory Fee to see if any adjustments are required based on advisory services provided to a client.
The Advisory Fee for the first month a client’s assets are under management with GR Financial will be
prorated. Thereafter, the Advisory Fee is payable on the first business day of the calendar month and is
based on each account’s asset value, calculated by each client’s qualified custodian, as of the last business
day of the prior calendar month. As a result, a client’s monthly Advisory Fee percentage may go up or
down based on asset size. The monthly Advisory Fee amount due is calculated by applying the monthly

    fee percentage (annual fee percentage divided by 12) to the previous month-end account(s) value(s).
    The account value includes cash, cash equivalents, and accrued interest and dividends.
    In addition to the Advisory Fees outlined above and the Performance Fees below, GR Financial charges an
    annual $35 technology fee. This fee is billed annually in September.

    When entering into an investment advisory agreement, clients authorize GR Financial to instruct their
    custodian to deduct Advisory Fees and the technology fee from their managed account(s). At the
    beginning of every month, GR Financial submits a statement/invoice to the clients’ custodian(s), which
    reflects the amount of the Advisory Fee to be deducted from each client’s account(s). The amount
    deducted each month will be reflected in each client’s custodian statement. Every September, GR
    Financial submits a statement/invoice to the clients’ custodian(s), which reflects the amount of the
    annual technology fee to be deducted from each client’s account(s). This amount will also be listed on
    each client’s custodian statement but is generally reflected as an advisory fee paid vs. a technology fee.

    Limited Negotiability of Asset-Based Advisory Fees

Although GR Financial has established the Advisory Fee schedule, we retain the discretion to negotiate
alternative fees on a client-by-client basis. Client facts, circumstances, and needs are considered in
determining the fee schedule. These factors include, among other considerations: the complexity of the
client assets to be placed under management, anticipated future additional assets, related accounts,
portfolio style, account composition and reports to be generated. The specific annual fee schedule is
identified in the signed investment advisory agreement the client enters into with GR Financial. In
addition, GR Financial has the discretion to waive its Advisory Fee for certain clients, such as for friends
and family of the Firm. Notably, GR Financial has clients that have different fee schedules than the one
reflected above and friends and family clients that are not charged an advisory fee.

    GR Financial Group generally requires a minimum initial investment of $250,000 to open an account but
    does reserve the right to accept or decline a potential client for any reason in its sole discretion.

Item 7         Types of Clients
 GR Financial provides advisory services to the following types of clients:

         Individuals (other than high net worth individuals)
         High net worth individuals
         Charitable organizations
         Corporations or other businesses 

When GR Financial provides investment advice to our clients, we are deemed a fiduciary under certain
federal regulations, and within the meaning of Title I of the Employee Retirement Income Security Act
(“ERISA”) and/or the Internal Revenue Code of 1986 (the “Code”) as applicable, which are laws
governing retirement accounts. The way we make money creates some conflicts with our clients’
interests. However, as a fiduciary, GR Financial and our supervised persons are required to always act
in our clients’ best interests, which means we must, at a minimum take the following steps:

      Meet a professional standard of loyalty and care when making investment recommendations.
      Always put our clients’ interests ahead of our own when making recommendations and
       providing services.
      Disclose all conflicts of interest and how the Firm addresses such conflicts.

      Adopt and follow policies and procedures designed to help ensure that we give advice and
       provide services that remain in each client’s best interest.
      Charge an advisory fee that is reasonable for our services.
      Not provide, or withhold, any information that could render our advice and/or services
       misleading.

In addition, when recommending to a client a rollover of their retirement account (e.g., 401K to an
IRA). GR Financial will perform an analysis to determine whether such a recommendation is in the
client’s best interest based on applicable facts and circumstances at the time of the recommendation. If
it is believed to be in a client’s best interest, then we will provide a document to the client outlining the
reasons we believe that the rollover would be in their best interest.