Hartford Financial Management Inc

ITEM 5            FEES and COMPENSATION

A. Fee schedules
 Our fees are based on the total market value of funds under management and are billed and are payable in advance
 at the beginning of each quarter. Depending on circumstances, fees can be negotiated. We make no fee adjustments
 during any fee period for appreciation or depreciation in account asset value during that period. We do not make fee
 adjustments or refunds when the total assets under management changes due to partial withdrawals by the client. The
 initial fee will be based on the initial Account Asset Value and will be pro-rated and will cover the period from the date
 the Account is accepted by Hartford Financial Management, Inc. through the last business day of the then current
 billing period. Thereafter, the quarterly fee will be based on Account Asset Value on the last business day of the
 previous quarter, and will become due the first business day of the current quarter. If additional cash, securities or
 other investments in excess of 20% of the prior quarter-ending value are accepted for management during the
 current quarter, an additional fee covering the total value of the newly accepted assets will be charged and will
 become due on the date of such acceptance. Such additional fee shall be determined by applying the foregoing fee
 schedules to the sum of Account Asset Values as of the end of the preceding quarter plus the Asset Value of such
 additional assets, subtracting from it the Quarterly Fee for such current quarter, and pro-rating the resulting fee over
 the balance of that quarter.
 For customized portfolios of individual securities
 with contracts dated April 1, 2009 or later, the fee schedule is:

 Minimum Fee - $7,500 per year, billed and payable quarterly
 1.0% per year of first $2,000,000 of assets under supervision
 0.60% per year of next $1,000,000 of assets under supervision
 0.50% per year of next $2,000,000 of assets under supervision
 0.35% per year of next $15,000,000 of assets under supervision
 0.30% per year of the balance over $20,000,000 of assets under supervision.

 For customized portfolios of individual securities with contracts dated before April 1, 2009, other fee
 schedules applied, depending on contract execution date or whether a negotiated fee schedule.
Other investment advisory programs or assignments:

Investment advisory relationships consisting of programs other than customized portfolios of individual
securities are billed and payable quarterly using a negotiated fee schedule. The unused portion of the
investment advisory fee for those programs is refundable upon termination of the agreement as described
below. We accept specific assignments to provide investment advisory services to dedicated pools of
funds such as growth equity pools, fixed income portfolios, cash management, etc. (We do not provide
investment advisory services to investment companies / mutual funds.) The fee schedule is the same as
above but negotiable for larger institutional pools. The unused portion of the investment advisory fee for
those assignments is refundable upon termination of the agreement as described below. We accept
specific assignments where we furnish investment advice through consultation which includes only the
review of investment programs, performance monitoring, venture evaluation, or company analysis, etc. In
individual situations, we will provide consultation to family owned businesses and related clients via a
financial planning analysis including assessment of assets and opportunities and overall financial and/or
business circumstances or considerations. We negotiate fees for these types of services on a case by
case basis depending on the scope of work to be performed and bill them on an hourly and contract basis.
The unused portion of the investment advisory fee is refundable upon termination of the agreement as
described below.

B. Method of payment
The client pays our quarterly investment advisory fees either by check made payable to our firm, or by authorizing in
writing for our firm to deduct our fees each quarter directly from one or more of the client's accounts.

 C. Other fees
 Clients incur other fees charged by third parties, including custodian fees, mutual fund expenses or trailer
 (“12B-1”) fees, and bank fees. Clients will incur brokerage and other transaction costs, which are
 discussed in greater detail in this brochure’s section on “Brokerage Practices”. None of these fees are
 paid to or accepted by Hartford Financial Management, Inc. or its employees.
 Our firm has an arrangement with an outside firm, DPL Financial Partners LLC (DPL) that enables us to
 evaluate insurance products such as life insurance and annuities as part of a client’s overall financial
 plan. We compensate DPL directly for the information they provide to us about 3rd party insurance
 companies and their products. Clients may choose to separately purchase these products; if they do they
 will incur other fees and costs paid to the 3rd party agency or insurer, not to us.

D. Timing of billing and payment. Fees due at termination.
Clients must pay our fees in advance, and are billed at the beginning of the quarter for which they are
being charged our fee.

Termination:
Either the client or Hartford Financial Management, Inc. may terminate the investment advisory agreement
at will by delivery of a written notice of termination to the other party to the advisory contract. The client’s
contract with our firm specifies the exact fee and termination terms for each account. The unused portion
of investment advisory fees is refundable upon termination of the agreement as specified in the client's
contract with HFM.

For accounts with contracts executed on or after April 1, 2002:
In the event of termination, the client will be entitled to a prorated refund of any pre-paid advisory fee,
based on the number of calendar days from the notice date of termination through the end of the period
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ITEM 7           TYPES of CLIENTS

Hartford Financial Management, Inc. provides investment advice to these types of clients:
    • Individuals and families
    • Trusts and estates
    • Endowments, foundations, and charitable organizations
    • Retirement plans such as pension or profit-sharing plans
    • Banks, savings and loans, credit unions
    • Corporations or business entities.

While we do not require an absolute minimum account size, our fee minimums usually drive the net
investable asset level at which it is practical for the potential client to engage our firm to deliver our
services. We consider the size of other family member’s or related accounts who are already clients
during negotiation for services.

ITEM 8         ANALYSIS METHOD, INVESTMENT STRATEGIES, RISK of
               LOSS

  Investing in securities using any strategy or analysis, whether on one’s own or with the guidance of
  an investment adviser, involves risk of various types. The types include the risk of loss of principal,
  loss of the original money or assets put into the investment, among others. Clients should be
  prepared to bear the risk of loss when investing, regardless of the type of investment program or
  types of securities purchased.

  In its investment advisory role, Hartford Financial Management, Inc. aims to gather information from
  each client about the client’s risk tolerance and ability to absorb risk, as well as the client’s financial
  resources and goals. We use the information supplied to guide our planning and investment choices
  for the client. We urge the client to keep us abreast of any changes in those characteristics. We
  also urge the client to make us aware of other investments not managed by us so that we can take
  the risk and characteristics of those other securities into account in the client’s overall picture.

  Our primary strategies in formulating investment advice or managing assets for most of our types
  of clients are the following: (strategies vary for institutional—bank and credit union—clients)

  •   Seek capital preservation
  •   Seek diversification
  •   Seek an approach customized to the client’s life or business events, which could also include
      needs for income or cash flow.
  •   Long-term orientation/holdings, although at times purchases held less than a year will be called
      for due to client circumstances.
  We generally rely on analysis of secular (long term, non-periodic) trends and cyclical trends as a
  basis for a fundamental approach to security evaluation and stock selection. However, trends
  and cycles observed in the past are no guarantee of the timing, magnitude and duration of future
  trends and cycles. We also but much less frequently consider technical analysis or charting, tools
  which must not be viewed as predictive either. Because past performance is no indicator of
  future results, however, the client should be aware that results will vary over time using any
  methodology and securities from any risk category. Clients should also be aware of their own
  tolerance for loss.
  Depending on the client’s investor profile, risk tolerance, needs, and financial plan, if suitable, we
  use in a client’s portfolio a selection, but not necessarily all, of the following securities:
  (Note that some securities considered for our institutional--bank or credit union--client portfolios are
  not necessarily appropriate for use in our individual/family or other types of client accounts.)
      •   exchange-listed or over-the-counter traded equities (stock) from domestic or foreign issuers
      •   bonds or other “fixed income” securities, including but not limited to corporate and municipal
          bonds, U.S. governmental securities.
      •   money market funds
      •   mutual fund shares, ETF (exchange-traded fund) shares

  The risks of the securities used most often above include but are not limited to:
     • risk of falling stock price of a company’s stock due to the impact of business or management
          problems, industry problems, natural disasters, negative items in the media, the reduction or
          discontinuation of payment of any dividends, broader securities market conditions, etc.;
     • risk of falling bond prices or defaults on interest payments, loss of principal, changes in
          alternatives’ interest rates, and other risks;
     • risk of falling mutual fund or ETF share values due to market or management issues;

   •    risk of falling values or changing yields on money market funds. Under revised
        Securities and Exchange Commission rules, during periods of market stress, money
        market funds temporarily put into place “liquidity fees” on investor redemptions or
        temporarily suspend investor redemptions (a "redemption gate").
   We also use but only where appropriate for only certain clients: commercial paper, certificates
   of deposit, warrants, covered options contracts on securities, futures contracts on intangibles,
   interests in partnerships investing in real estate, oil and gas interests, mortgage-backed and
   asset-backed securities, among others. The types, degrees, and sources of risk of these
   securities are too varied to discuss in full here, but those risks involve the potential loss of money
   for the client in varying degrees. Not all securities are appropriate for all clients.

Financial Planning: During financial planning, we can help a client identify the potential beneficial
role of some 3rd party financial products, such as 529 education savings plans or insurance
products. We can help analyze some alternatives among them. We can refer a client out to a 3rd
party provider of these products, but we do not earn commissions on them.

529 Plans: A 529 plan is a tax-advantaged savings plan designed to encourage saving for future
education costs. 529 plans are sponsored by states, state agencies, or educational institutions,
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