Heaton Financial PC

Item 5: Fees and Compensation

A. Fee Schedule

Investment Supervisory Services Fees

                                                   Asset         Equity      Trading
        Portfolio Type         Fixed Income
                                                 Allocation
          $1 - $50,000            1.00%            1.50%         1.75%        N/A
       $50,001 - $100,000         0.85%            1.25%         1.50%        N/A
       $100,001 - $250,000        0.75%            1.00%         1.25%        N/A
       $250,001 - $500,000        0.60%            1.00%         1.15%        N/A
      $500,001 - $1,000,000       0.50%            0.90%         1.00%        N/A
       Above $1,000,000           0.35%            0.75%         0.85%        N/A

These fees are negotiable and HF may offer to discount the fee based upon the client’s
relationship to an HF employee, the complexity of managing the accounts, type of assets
held in accounts, the level and frequency of service required by the client, and the total
amount of assets under management. Fees are paid quarterly in arrears and clients may
terminate their contracts with five days’ written notice. Because fees are charged in
arrears, no refund policy is necessary. Clients may terminate their accounts without
penalty within 5 business days of signing the advisory contract. Advisory fees are
withdrawn directly from the client’s accounts with client written authorization.

Retirement Account Rollovers

As described in Item 4, if HF recommends that a client roll over assets from an employer-
sponsored retirement plan into an IRA managed by HF, HF generally receives an advisory
fee on those assets. As a result, HF has a financial incentive to recommend a rollover.
Clients should carefully consider the factors discussed in Item 4 before deciding whether
to roll over retirement plan assets.

Financial Planning Fees

Hourly Fees
The hourly fee for financial planning services is $200. The fees are negotiable and we may
offer a discount to select friends, family, and long-term clients. Fees are paid in arrears
upon completion. Because fees are charged in arrears, no refund is necessary. Clients may
terminate their contracts without penalty within five business days of signing the

       advisory contract. A separate letter of engagement may be used to outline the scope of
       the financial services to be provided.

       B. Payment of Fees

       Payment of Investment Supervisory Fees
       For clients who provide written authorization to their custodian, advisory fees will be
       withdrawn directly from the client’s accounts. Fees are paid quarterly in arrears. Clients
       will receive, at least quarterly, a statement from the Custodian that reflects the advisory
       fee paid to HF. Clients who do not authorize payment of Advisory fees directly from their
       account will be invoiced and billed directly with payments due upon receipt of the
       invoice. Clients should verify the accuracy of any fees paid.

       Payment of Financial Planning Fees
       Hourly Financial Planning fees are paid in arrears upon completion. Because fees are
       charged in arrears, no refund is necessary. Fees may be paid by check or cash.

       C. Clients Are Responsible For Third Party Fees

       Clients are responsible for the payment of any third-party fees (i.e. custodian fees, mutual
       fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and
       expenses charged by HF. Please see Item 12 of this brochure regarding broker/custodian.

       D. Prepayment of Fees

       HF collects its fees in arrears. It does not collect fees in advance.

       E. Outside Compensation for the Sale of Investments to Clients

       Neither HF nor its supervised persons accept any compensation for the sale of securities
       including asset-based sales charges or services fees from the sale of mutual funds.
       However, representatives of HF may be licensed as insurance agents to sell insurance
       products and may receive insurance commissions for the placement of those products.
       The sale of such products creates a conflict of interest that is further described in the
       conflicts of interest section on page 7 section C. Our primary focus is on the investment
       advisory business, and we expect that insurance related products will be less than 10% of
       the representative’s business.

Item 7: Types of Clients
HF generally provides investment advice and/or management supervisory services to the
following types of clients:

           ❖ Individuals
           ❖ High-Net-Worth Individuals
           ❖ Corporations or Business Entities
Minimum Account Size

There is no account minimum except for the Trading portfolio which is $100,000 initial deposit.