Harlow Wealth Management Inc

Item 5 - Fees and Compensation

Investment Management Fees

Management fees vary depending on whether accounts are managed internally or on an outside
management platform. Generally, fees charged to clients may be up to 1.55% of assets under
management per annum. Harlow, at their sole discretion, may negotiate fees based on the size and
complexity of a client’s account.

Fees are charged monthly in arrears and are based on average, daily account value as of the end of
the applicable month as reported by the custodian. Fees are generally debited directly from a client’s
account by custodian at the direction of the client, Harlow, or the applicable platform provider.

Clients may be required to provide written authorization to their account’s custodian in order for
management fees to be deducted from their account. If a client’s account does not have a sufficient
cash or money market balance to cover the fees or is restricted from automatic debiting of fees,
additional funds, subject to certain restrictions for IRA accounts and Qualified Retirement Plans, may
be deposited to the account. Alternatively, clients can make payment in an alternative manner

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acceptable to Harlow. If a client does not deposit additional funds or otherwise make the payment,
securities in the account may be sold in an amount sufficient to cover the fees. The client’s custodian
will reflect the amount of the fee deduction on their account statement.

Clients may terminate their Investment Management Agreement without penalty within five (5)
business days after entering into it. Any prepaid investment management fees will be refunded.

After five (5) business days, clients may terminate Harlow’s services at any time by providing written
notice to Harlow Wealth Management, Inc. For an account billed in advance, clients will be entitled
to a pro-rata refund of any prepaid fee based upon the number of days remaining in the period after
the effective date of the termination. For an account billed in arrears, clients will be billed for the
partial period.

A client’s death will not terminate an investment advisory agreement or authority granted to Harlow.
In order to make any changes to the account, Harlow must receive written notification of a client’s
death and notice of who will be working with the Firm on the client’s account. Harlow will then work
with the client’s representative to help them make the appropriate choices for the account.

Sub-Advisor’s Fees

Sub-Advisors managing client investments usually charge fees based on the assets placed under their
management, and this fee is separate from Harlow’s fees as detailed above. The amount of fees
charged by Sub-Advisors, method of payment, and frequency of billing are disclosed in the Sub-
Advisor’s written disclosure documents provided in advance. These fees may be negotiable
depending on the policies of the Sub-Advisors.

The Sub-Advisor's written disclosure documents disclose other charges and practices associated with
the management of your investments. Examples of these charges are custodial fees, deferred sales
charges, if any, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, taxes on
brokerage accounts and securities transactions. Some Sub-Advisors charge a fee for mailing paper
account statements. Some Sub-Advisors begin charging advisory fees upon funding an account as
opposed to waiting until management begins. Harlow urges you to read the Sub-Advisor’s disclosure
documents and ask us if you have any questions.

Mutual funds and exchange-traded funds also charge separate management fees, which are
disclosed in a mutual fund’s prospectus. Harlow does not receive any of these commissions, charges,
and/or fees.

Clients have the right to terminate your agreement with a Sub-Advisor without penalty within five

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(5) business days. Otherwise, termination of your agreement and the return of unearned prepaid
fees are described in the Sub-Advisor’s disclosure documents which will be provided to you on an
annual basis by the Sub-Advisor.

AEWM Program Fees

When services are provided through AEWM, Harlow pays AEWM a percentage of fees earned by the
Firm and based upon the assets managed for clients. This fee is paid to AEWM from the fees you pay
to Harlow. A more detailed description of fees related to AEWM’s program is located in AEWM’s
disclosure brochure which will be provided to you by AEWM on an annual basis.

Services provided through AEWM’s managed account program are offered through a wrap fee
program. If a client receives services through the wrap fee program, they will only pay fees based on
assets under management and will not pay a separate commission, ticket charge, or custodian fee,
for the execution of transactions in your account.

Further information pertaining to AEWM’s wrap fee program is available in AEWM’s Form ADV Part
2A which is provided to clients who are utilizing investments through AEWM’s wrap program.

Harlow may also provide investment advisory services to participants in 401K plans. Harlow does
not provide investment management services to any ERISA Plans and does not act as a Fiduciary
under ERISA. Generally, fees charged to participants are based on the participant’s assets under
management and as follows:

   •   Startup to $1 million         1.00%
   •   $1 million to $4 million      0.75%
   •   $4 million to $8 million      0.60%
   •   $10 million to $20 million    0.35%
   •   $20 million up                Fixed Dollar

Financial Planning Fees

Financial planning services are offered either as part of an ongoing investment management
relationship or as a stand-alone service.

When provided as part of an ongoing investment management relationship, financial planning services
...

Item 7 – Types of Clients

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Harlow provides advisory services to individual investors, participants in 401k and profit-sharing
plans, trusts, estates, and businesses. Although Harlow has a minimum account size of $500,000, this
requirement may be waived at the Firm’s discretion. Additionally, Sub-Advisors recommended to a
client may require a minimum account balance to open or maintain an account and/or may charge a
minimum annual fee.