Harborfront Financial LLC

ITEM 5: FEES AND COMPENSATION

Fees for LPL Advisory Programs

The account fee charged to the client for each LPL advisory program is negotiable, subject to the
following maximum account fees:

       Manager Access Select         3.0%*
       OMP                           2.5%
       PWP                           2.5%
       SWM                           2.5%
       MWP                           2.65%**
       SMS                           0.95%***
       GWP                           1.35%****

* The maximum Manager Access Select account fee for new accounts was reduced to 2.5%
effective July 3, 2017.
** The MWP account fee consists of an LPL program fee, a strategist fee (if applicable) and an
advisor fee of up to 2.00%. Accounts remaining under the legacy fee structure may be charged
one aggregate account fee, for which the maximum account fee is 2.50%. See the MWP program
brochure for more information
** The SMS fee consists of an LPL program fee of 0.20% (subject to a minimum program fee of
$250), and an advisor fee of up to 0.75%.
*** GWP Managed Service clients are charged an account fee consisting of an LPL program fee
of 0.35% and an advisor fee of up to 1.00%. In the future, a strategist fee may apply. However,
LPL Research currently serves as the sole portfolio strategist and does not charge a fee for its
services. FutureAdvisor is compensated directly by LPL for its services, including the Algorithm
and related software, through an annual sub-advisory fee (tiered based on assets under
management by FutureAdvisor, at a rate ranging from 0.10% to 0.17%). As each asset tier is
reached, LPL’s share of the compensation shall increase, and clients will not benefit from such
asset tiers.

GWP Educational Tool provides access to sample recommendations at no charge to users.
However, if users decide to implement sample recommendations by executing trades, they will be
charged fees, commissions, or expenses by the applicable broker or adviser, as well as underlying
investment fees and expenses.

Account fees are payable quarterly in advance, except that the SMS fee is paid in arrears on the
frequency agreed to between client and Harborfront.

                                                                HARBORFRONT FINANCIAL GROUP

Excluding SMS and GWP, LPL serves as program sponsor, investment advisor and broker-dealer
for the LPL advisory programs. In the Managed Service of GWP, LPL is appointed by each client
as custodian of account assets and broker-dealer with respect to processing securities transactions
for the accounts. In general, FutureAdvisor, in its capacity as investment advisor, will submit
transactions through LPL; however, FutureAdvisor may choose to execute transactions through a
broker-dealer other than LPL, subject to its duty to seek to achieve best execution. When securities
transactions are effected through LPL, there are no brokerage commissions charged to the account.
If FutureAdvisor chooses to execute a transaction through a broker-dealer other than LPL, the
execution price may include a commission or fee imposed by the executing broker-dealer. In
evaluating whether to execute a trade through a broker-dealer other than LPL, Future Advisor will
consider the fact that the account will not be charged a commission if the transaction is effected
through LPL.

Harborfront and LPL may share in the account fee and other fees associated with program
accounts. Associated persons of Harborfront may also be registered representatives of LPL. Under
SMS, LPL serves as investment advisor but not the broker-dealer. Harborfront and LPL may share
in the advisory portion of the SMS fee.

Certain Conflicts of Interest

Harborfront receives compensation as a result of a client’s participation in an LPL program.
Depending on, among other things, the type and size of the account, type of securities held in the
account, changes in its value over time, the ability to negotiate fees or commissions, the historical
or expected size or number of transactions, and the number and range of supplementary advisory
and client-related services provided to the client, the amount of this compensation may be more or
less than what the Harborfront would receive if the client participated in other programs, whether
through LPL or another sponsor, or paid separately for investment advice, brokerage and other
services.

The account fee may be higher than the fees charged by other investment advisors for similar
services. For instance, FutureAdvisor offers direct-to-consumer services similar to GWP.
Therefore, clients could generally pay a lower advisory fee for algorithm-driven, automated
(“robo”) investment advisory services through FutureAdvisor or other robo providers. However,
clients using such direct robo services will forgo opportunities to utilize LPL-constructed model
portfolios or to work directly with a financial advisor.

Clients should consider the level and complexity of the advisory services to be provided when
negotiating the account fee (or the advisor fee portion of the account fee, as applicable) with
Harborfront. With regard to accounts utilizing third-party portfolio managers under aggregate, all-
in-one account fee structures (including MAS, PWP and the legacy MWP fee structure), because
the portion of the account fee retained by Harborfront varies depending on the portfolio strategist
fee associated with a portfolio, Harborfront has a financial incentive to select one portfolio instead
of another portfolio.

Please refer to the relevant LPL Form ADV program brochure for a more detailed discussion of
conflicts of interest.

                                                                 HARBORFRONT FINANCIAL GROUP

Harborfront will provide investment advisory services and portfolio management services but will
not provide custodial or other administrative services. At no time will Harborfront accept or
...

ITEM 7: TYPES OF CLIENTS

Harborfront provides investment advice to many different types of clients. These clients generally
include individuals, corporations, trusts and estates, charitable organizations, and other business
entities.

Minimum Account Size

Harborfront does not require any minimum amount of assets to open or maintain an account.