GWN Securities Inc

Item 5 Fees and Compensation
Managed Accounts

    1. GWN Managed Account Program Fees

The standard Program Fees for the GWN Managed Account Program are set forth below and are
expressed in terms of an annual percentage of quarter-ending values:

                        Annual Fee Schedule for GWN Managed Account Program
                          SAM, HDSAM, MOM, DRM, StAR, and CyAM Programs

                       Account Value                       Maximum Annual Fee
                       First $250,000                           1.50%
                       $250,000 - $500,000                      1.25%
                       $500,000 - $1,000,000                    1.00%
                       Amounts over $1,000,000                  0.50%

The annual fee schedule above shall be applied to your account on a "blended" basis. For avoidance
of doubt, and as an example of how our blended billing procedures function, a hypothetical client
account containing a balance of $1,000,000 would pay 1.50% on the first $250,000 of the client's
account balance annually; 1.25% on the next $250,000 of the client's account balance annually; and
1.00% on the remaining $500,000 of the client's account balance annually.

To open and maintain a GWN Managed Account, the minimum account value for a qualified account is
$2,000, with a $10,000 minimum for all others. In addition to the advisory fee, a 0.50% custodial
fee will be charged on qualified accounts. The custodial fee covers all trading and custody charges
imposed by the qualified custodian for qualified accounts. There are no separate custody charges for
non-qualified accounts since it is included in the gross fee paid by the client.

Our annual portfolio management fee is billed and payable, quarterly in arrears, based on the balance
at end of billing period as determined by the qualified custodian or by the third-party administrator for
qualified accounts.

Please refer to the following subsection below for further information about the compensation we may
earn and the conflicts of interest such compensation creates: Compensation for the Sale of Securities
or Other Investment Products; Compensation for the Sale of Insurance Products; and Product Sponsor
Compensation.

     2. GWN Premier Program Fees ("Premier Program")
Recordkeeping, advisory fee, and service charges for accounts participating in the GWN Premier
Select Program and GWN Premier Fund Choice Program are negotiated on a client-by-client basis
but shall not exceed 2.00% per year. Recordkeeping and advisory fees are billed quarterly in arrears.

The American Funds Direct program has an annual fee of up to 2%. Accounts in the American Funds'
Direct Program are billed quarterly in arrears and fees are deducted directly from the applicable
American Funds' account. No sales charges are paid by the client for the American Funds mutual
funds since they are invested in the F2 share class. Fees are billed quarterly based on the Client's start
date in the American Funds Direct Program.

In addition to recordkeeping fees and advisory fees, service fees may apply to your account.
Depending on the trading platform in which the account resides, transaction costs and/or short-term
redemption fees, either platform or fund specific may be incurred by the account. These fees are
assessed to the account at the time they are being incurred.

The minimum account balance for a qualified account is $2,000, with a $10,000 minimum for taxable
(non-retirement) accounts. GWN will receive a quarterly fee billed in arrears equal to a percentage of
the market value of all assets held within the Participant's account on the last business day of the
quarter or upon withdrawal from such account prior to the quarter's end. GWN has the right but not the
obligation to accept a minimum below $2,000. GWN reserves the right to charge and collect the asset-
based fee on a monthly basis, rather than on a quarterly basis,

Fees are based on the account value as determined by the qualified custodian for non-retirement
accounts and as determined by the third-party administrator for retirement accounts. For accounts
billed in arrears, the account value as of the last day of the previous month is used to calculate the
billing.

New deposits made to legacy accounts with SBG or Valic will pay compensation (commissions) to
GWN in its capacity as a broker-dealer. New deposits into an existing variable annuity contract that
originally paid a commission will also pay commissions on the new deposit to GWN in its capacity as a
broker-dealer.

MAP Program

Recordkeeping, advisory fee, and service charges for accounts participating in the MAP Program are
negotiated on a client-by-client basis but shall not exceed 2.00% per year. Recordkeeping and
advisory fees are billed quarterly in arrears. In addition to recordkeeping fees and advisory fees,
service fees may apply to your account. Depending on the trading platform in which the account
resides, transaction costs and/or short-term redemption fees, either platform or fund specific may be
incurred by the account. These fees are assessed to the account at the time they are being incurred.

The minimum account balance for a qualified account is $2,000, with a $10,000 minimum for all other
accounts with the exception of Toews models which have a $25,000 minimum for non– qualified
accounts. GWN will receive a quarterly fee billed in arrears equal to a percentage of the market value
of all assets held within the Participant's account on the last business day of the quarter or upon
withdrawal from such account prior to the quarter's end. GWN has the right but not the obligation to
accept a minimum below $2,000. GWN reserves the right to charge and collect the asset-based fee on
a monthly basis, rather than on a quarterly basis,

Fees are based on the account value as determined by the qualified custodian for non-retirement
...

Item 7 Types of Clients
We offer investment advisory services to individuals, high net worth individuals, and business entities.

To open and maintain an advisory account, we generally require the minimum account values for the
following types of accounts:

    • Qualified Accounts - $2,000 minimum account size or $200 in contributions per month
         • Accounts participating in the Security Benefit Platform - $10,000 minimum account size
              or $100 in contributions per month
    • Non-Qualified Accounts - $10,000 minimum account size

However, at our discretion, we may waive this minimum account size. For example, we may waive the
minimum if you appear to have significant potential for increasing your assets under our management.

Certain third-party managers and their related platforms, models or custom portfolios may have
minimum account values or fees. Please refer to the third-party manager's ADV 2A Brochure for
additional information related to minimum requirements. Third-party manager minimums are not
subject to our control, and therefore, may not be negotiable or waived.