Holloway Wealth Management LLC

Fees and Compensation - Item 5

HWM charges fees based on a percentage of assets under management for its advisory services.

Portfolio Management Services Fees
If you decide to engage HWM for portfolio management services, we will charge an annual fee based
upon a percentage of the market value of the assets being managed. Our fee for portfolio management
services is set forth in the following fee schedule:

        Portfolio Size                            Annualized Fee
        First $1,000,000                          1.50%
        Over $1,000,000                           0.50%

HWM allows the accounts for members of the same household to be combined for fee-paying purposes.
We combine the account valuations to assist you in meeting fee breakpoints and therefore lowering the
overall fee level. HWM extends this option to all accounts residing in the same household.

Generally, the annual fee for portfolio management services is billed quarterly in arrears based on the
market value of the assets on the last day of the preceding quarter or the average quarterly balance.
Since this fee is negotiable, the exact fee paid by the Client will be clearly stated in the advisory
agreement signed by the Client and the Firm. Because HWM’s fees may be negotiated, not all clients will
pay the same fees. A client may pay a higher or lower fee depending on considerations such as the size
of the client’s account, the amount of time the client has maintained an account with HWM, and/or the
combined market value of related portfolios.

The qualified custodian holding the Client’s funds and securities will pay the fees directly to HWM
provided the Client supplies written authorization permitting this payment. HWM will not have access to
Client funds for payment of fees without written consent by the Client. Further, the qualified custodian
agrees to deliver an account statement, at least quarterly, directly to the Client, showing all
disbursements from the account. We encourage the Client to review all account statements for
accuracy. HWM will receive a duplicate copy of the statement that was delivered to the Client. Fees are
usually deducted from a designated Client account to facilitate billing.

Clients should note that our annual fee is exclusive of, and in addition to the custodial fee charged by
the qualified custodian. Please see Item 12 – Brokerage Practices for further information on brokerage
services.

Holloway Wealth Management, LLC
Form ADV Part 2A

At the inception of portfolio management services, the first quarter’s fees will be calculated on a pro-
rata basis. The agreement between HWM and the Client will continue in effect until either party
terminates in accordance with the terms of the agreement. HWM’s annual fee will be pro-rated through
the date of termination and any remaining balance will be charged or refunded to the Client, as
appropriate, in a timely manner.

We recommend that you compare our invoices with the statement(s) you receive from the qualified
custodian. If you see something that is inaccurate, please call our main office number, located on the
cover page of this brochure.

Pension Consulting Services Fees
The compensation arrangement for pension consulting services is based on fixed fees, or a percentage
of the plan assets. Services will be negotiated on a case-by-case basis. The exact services to be provided,
the fee to be paid by the Client, fee payment arrangements, how to terminate the contract, and other
terms will be clearly stated in the pension consulting agreement signed by the Client and HWM.

Clients who choose to have HWM’s fee deducted directly from their account must provide
authorization. The qualified custodian holding Client funds and securities will send an account statement
on at least a quarterly basis. This statement will detail account activity. Clients are encouraged to review
each statement for accuracy.

Additional Fees and Expenses
Historically, HWM was the sponsor and portfolio manager to a wrap fee program. The wrap fee program
is no longer available to new clients and HWM has taking steps to transition clients who are invested in
the program to a non wrap arrangement. As a result, during this transitional period HWM has made its
advisory fee schedule uniform between its wrap and non wrap programs. Additionally, HWM is in the
process of executing new agreements with all clients who were under a Wrap Program agreement. As of
March 2020, all Clients that will be transitioning to the non wrap portfolio management arrangement
have received updated agreements and the firm strongly encourages such clients to execute and return
these agreements to HWM.

The fees HWM charges are negotiable based on the amount of assets under management, complexity of
Client goals and objectives, and level of services rendered. As described above, the fees are charged as
described and are not based on a share of capital gains of the funds of an advisory Client. All fees paid to
HWM for investment advisory services are separate and distinct from the fees and expenses charged by
mutual funds or exchange traded funds to their shareholders. These fees and expenses are described in
each fund's prospectus. These fees generally include a management fee, other fund expenses, and a
possible distribution fee. If the fund also imposes sales charges, a Client may pay an initial or deferred
sales charge.

Mutual funds generally offer multiple share classes based upon certain eligibility and/or purchase
requirements. For instance, in addition to retail share classes (typically referred to as class A, class B and
class C shares), mutual funds may also offer institutional share classes or other share classes that are
specifically designed for purchase by investors who meet certain specified eligibility criteria, including,
for example, whether an account meets certain minimum dollar amount thresholds or is enrolled in an
...

Types of Clients - Item 7

We offer investment advisory services to individuals, pension and profit sharing plan participants, trusts,
estates, charitable organizations, corporations, and other business entities.

HWM requires a minimum of $250,000 to open and maintain an advisory account. At our sole
discretion, we may waive this requirement. This requirement can be met by combining two or more
accounts owned by you or related family members.

                  Methods of Analysis, Investment Strategies and Risk of Loss - Item 8

The following are different methods of analysis that we may use when providing you with investment
advice:

    •   Fundamental Analysis – fundamental analysis is a technique that attempts to determine a
        security’s value by focusing on underlying factors that affect a company's actual business and its
        future prospects. The term refers to the analysis of the economic well-being of a financial entity
        as opposed to only its price movements.
    •   Technical Analysis – technical analysis is a technique that relies on the assumption that current
        market data (such as charts of price, volume, and open interest) can help predict future market
        trends, at least in the short term. It assumes that market psychology influences trading and can
        predict when stocks will rise or fall.

We utilize investment strategies and model portfolios developed in-house or by an unaffiliated third
party investment adviser. HWM generally will follow the third party investment adviser’s
recommendations. However, HWM can modify or override the third party investment adviser’s model
portfolio recommendations or replace it altogether with another third party investment adviser’s model
portfolio at its discretion. HWM will provide the client with information about any third party
investment adviser selected. Prior to engaging the services of any unaffiliated third party investment
adviser and thereafter on a periodic basis, HWM will conduct a due diligence review and will maintain
records of the review in the Firm’s compliance files.

We may use one or more of the following investment strategies when advising you on investments:

    •   Long Term Purchases – securities held for over a year.
    •   Short Term Purchases – securities held for less than a year.
    •   Trading – securities held for less than 30 days.

The investment advice provided along with the strategies suggested by HWM will vary depending on
each Client’s specific financial situation and goals. This brief statement does not disclose all of the risks
and other significant aspects of investing in financial markets. In light of the risks, you should fully
understand the nature of the contractual relationship(s) into which you are entering and the extent of
your exposure to risk. Certain investing strategies may not be suitable for many members of the public.
You should carefully consider whether the strategies employed would be appropriate for you in light of
your experience, objectives, financial resources and other relevant circumstances. Certain investment
strategies may utilize a concentrated portfolio of investments. Concentrated portfolios generally hold

Holloway Wealth Management, LLC
Form ADV Part 2A

the securities of a limited number of companies and, therefore, may be more volatile because the risk
specific to each company may represent a larger portion of assets. It is likely that the performance of
these portfolios will differ significantly from that of the broad equity market.

General Investment Risk: All investments come with the risk of losing money. Investing involves
substantial risks, including complete possible loss of principal plus other losses and may not be suitable
for many members of the public. Investments, unlike savings and checking accounts at a bank, are not
insured by the government to protect against market losses. Different market instruments carry
different types and degrees of risk and you should familiarize yourself with the risks involved in the
particular market instruments you intend to invest in.

Loss of Value: There can be no assurance that a specific investment will achieve its investment
objectives and past performance should not be seen as a guide to future returns. The value of
investments and the income derived may fall as well as rise and investors may not recoup the original
amount invested. Investments may also be affected by any changes in exchange control regulation, tax
laws, withholding taxes, international, political and economic developments, and government, economic
or monetary policies.

Interest Rate Risk: Fixed income securities and funds that invest in bonds and other fixed income
securities may fall in value if interest rates change. Generally, the prices of debt securities rise when
interest rates fall, and their prices fall when interest rates rise. Longer-term debt securities are usually
more sensitive to interest rate changes.

Credit Risk: Investments in bonds and other fixed income securities are subject to the risk that the
issuer(s) may not make required interest payments. An issuer suffering an adverse change in its financial
condition could lower the credit quality of a security, leading to greater price volatility of the security. A
lowering of the credit rating of a security may also offset the security's liquidity, making it more difficult
to sell. Funds investing in lower quality debt securities are more susceptible to these problems and their
value may be more volatile.