HD Money Inc

Item 5: Fees and Compensation

do not carry embedded 12b-1 fees (sometimes referred to as “I-Shares,” depending on the
mutual fund sponsor). Wrap fee programs offer investment services and related transaction
services for one all-inclusive fee (except as may be described in the applicable wrap fee program
brochure). The trading costs are typically absorbed by the firm and/or the investment
representative. If a client’s account holds A-Shares within a wrap fee program, the firm and/or its
investment adviser representative avoids paying the transaction fees charged by other mutual
fund classes, which in effect decreases the firm’s costs and increases its revenues from the
account. Effectively, the cost is transferred to the client from the firm in the form of a lower rate
of return on the specific mutual fund. This creates an incentive for the firm or investment adviser
representative to utilize such funds as opposed to those funds that may be equally appropriate
for a client but do not carry the additional cost of 12b-1 fees. As a policy matter, the firm does
not allow funds that impose 12b-1 or revenue sharing fees on the client’s investment within its
wrap fee programs. Clients should understand and discuss with their investment adviser
representative the types of mutual fund share classes available in the wrap fee program and the
basis for using one share class over another in accordance with their individual circumstances
and priorities.

                            Part 2A of Form ADV: HD Money, Inc. Brochure

Item 7: Types of Clients
HDM generally provides investment advice to individuals, trusts, estates, or charitable
organizations, corporations, or business entities.
HDM has no minimum fee or portfolio requirements. Separate account managers utilized by
HDM may have a minimum portfolio fee or size as a prerequisite to establishing accounts.
Please refer to the applicable manager’s disclosure brochure.

                           Part 2A of Form ADV: HD Money, Inc. Brochure