Growstrong Wealth Strategies LLC

Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
GrowStrong offers discretionary direct asset management services to advisory Clients.
GrowStrong charges an annual investment advisory fee based on the total assets under
management as follows:
             Assets Under Management                 Annual Fee         Monthly Fee
                 First $0 - $250,000                   2.00%             0.1667%
            The next $250,001 - $500,000               1.75%             0.1458%
           The next $500,001 - $1,000,000              1.50%             0.1250%
          The next $1,000,001 - $2,000,000             1.25%             0.1041%
              Amounts over $2,000,001                  1.00%             0.0833%
The annual fee may be negotiable based upon certain criteria (e.g., historical relationship,
type of assets, anticipated future earning capacity, anticipated future additional assets, dollar
amounts of assets to be managed, related accounts, account composition, negotiations with
Clients, etc.). GrowStrong considers cash to be an asset class, and as such is included in fee
calculations. Also, to be noted, at times fees will exceed the money market yield. Fees are
billed monthly in arrears based on an average daily balance of the account for the month.
Additionally, this is a blended fee schedule, the asset management fee is calculated by

applying different rates to different portions of the portfolio. Accounts within the same
household will be combined for a reduced fee unless otherwise instructed by the client.
The calculation for the average daily balance is based on the formula (A/D) x F.
A = the sum of the daily balances in the billing period
D = number of days in the billing period
F = monthly management fee
For example (based on monthly billing period): the first step taken using the average-
daily-balance calculation method would be to take the average of the values of the Client’s
account over the course of the entire month. For instance, 25 days at $1 million plus six days
at $500,000 averages out to approximately $903,225. This account would be charged
$1,285.28 for the month.
         AUM               Monthly Fee        Total
         First $250,000 x .1667 =             $416.75
         Next $250, 000 x .1458 =             $364.50
         Next $403,225 x .1250 =              $504.03
         Grand total for the month            $1,285.28
The investment advisory fee will be billed directly to the Clients account at the Custodian,
and the Custodian will deduct the fee for the Account. GrowStrong will not be compensated
based on the basis of a share of capital gains or capital appreciation of the assets in the
Account. Please see Item 15 for more information regarding direct deduction.

Variable Annuity and Life Management
The fees for these services will be based on a percentage of Assets Under Management and
will not exceed an annual fee of 1.5% of the assets managed. Fees will be disclosed prior to
Client signing the Investment Advisory Agreement.
GrowStrong’s fees are billed monthly or quarterly (depending on Client election) in arrears
based on the amount of assets managed as of the close of business on the last business day
of the previous billing period or based on the average daily balance. Advisory fees will be
paid in the following ways:
   •   Deduct from another non-qualified Client’s account held with GrowStrong
   •   Deduct from another qualified account if eligible, i.e., over 59 ½
   •   Direct billing to the Client payable within 10 days of invoice presentation
   •   Deduct from Client’s annuity account
The annual fee may be negotiable based upon certain criteria (e.g., historical relationship,
type of assets, anticipated future earning capacity, anticipated future additional assets, dollar
amounts of assets to be managed, related accounts, account composition, negotiations with
Clients, etc.). Accounts within the same household will be combined for a reduced fee.
Lower fees for comparable services may be available from other sources. Clients may
terminate their account within five (5) business days of signing the Investment Advisory
Agreement with no obligation and without penalty. After five days Clients may terminate
advisory services with thirty (30) days written notice. For accounts opened or closed mid-

billing period, fees will be prorated based on the day’s services are provided during the given
period. All unpaid earned fees will be due to GrowStrong. Client shall be given thirty (30)
days prior written notice of any increase in fees, and Client will acknowledge, in writing, any
agreement of increase in said fees.

THIRD PARTY MANAGERS
Howard Capital Management, Inc. (“HCM”)
GrowStrong has entered into a Solicitor Agreement with Howard Capital Management, Inc.
(“HCM”). HCM is a Registered Investment Advisor registered with the Securities and
Exchange Commission and provides investment portfolios and supervisory services. When
acting as a solicitor the third-party money manager will deduct fees from the client account
and will pay GrowStrong their portion of the fee.
For client’s utilizing HCM’s management services, HCM agrees to pay GrowStrong a referral
fee. GrowStrong and HCM shall execute a Solicitor Referral Fee Schedule which sets forth
the referral fee to be paid to GrowStrong. The fees charged by HCM will be as follows:
          Program                      Annual Client Fee          GrowStrong Solicitor Fee
 Separately Managed Accounts
                                       Maximum of 2.20%                 ½ the Annual Fee
            (SMA)
                                  Annual advisory fees charged
      HCM Mutual Fund for         internally within the fund as
                                                                        0.75% Annually
 Self-Directed Accounts (SDBA)       specified in each fund's
                                           prospectus
...

Item 7: Types of Clients
Description
GrowStrong generally provides investment advice to individuals, high net worth individuals,
trusts and small businesses.
Client relationships vary in scope and length of service.
Account Minimums
GrowStrong does not require a minimum account size open an account.