Hornor Townsend & Kent LLC

Item 5. Fees and Compensation

HTK and Advisers charge fees based on the type of advisory services provided to the client. Certain fees are
negotiable and may include hourly fees, fixed fees, or a percentage of assets under management.

Fee Determination

Fees that are charged will consider the following factors:

    −   The complexity and time involved in the work performed.
    −   The degree of responsibility HTK and the Adviser have over the account.
    −   The needs and characteristics of the client.
    −   The types of investments and the costs involved in providing the service(s) selected.

Billing and Refunds

Fees may be billed in advance or in arrears. Clients paying in advance may be entitled to a prorated refund of
any prepaid fees for services not received upon termination of the agreement.

Detailed information regarding fees and compensation for each of the HTK advisory services programs is provided
immediately below.

Fees for Advisory Services with TPAMs

For advisory services with TPAMs, HTK charges up to 1.5 percent (1.5%) of the client's account value. This does
not include manager fees and other charges associated with the TPAM program.
  HTK                                                                                            Page 7 of 23

Co-Advisory Fee Structure

When HTK and its Adviser act as Co-Adviser, taking a more active role in advisory services provided to the client,
a portion of the advisory fee charged by the TPAM is paid to HTK and the Adviser. In some cases, the Adviser may
add a fee to the TPAM fee for performance of certain advisory services. Clients should review the investment
advisory agreement and the TPAM’s Disclosure Brochure for further information regarding the advisory fee
charged for the selected TPAM. For details related to specific TPAM fees, please see the applicable TPAM
Disclosure Brochure.

Promoter Fee Structure

When HTK and its Advisers act as a Promoter and introduce consumers to the TPAM, the TPAM pays HTK a
Promoter Fee. In some instances, HTK and the Adviser will share the Promoter fee; in other cases, HTK may
assess a separate fee in addition to the Promoter fee. The Promoter Disclosure Statement, provided to consumers
at the time of referral, will specify the fee paid to HTK.

Cost Comparisons and Discounts

The same or similar services to those described above may be available elsewhere to clients at a lower cost,
including through a wrap fee program. HTK offers some employees, its Advisers, and family members a discount
or waiver of some or all fees.

Financial Planning and/or Consulting Services Fees

For Financial Planning and/or Consulting Services, HTK fees are negotiable and may vary based on the complexity
of the consumer’s profile and the services requested. When an Adviser maintains their own fee schedule, the
cost of similar services provided by that Adviser may be higher or lower than the fees quoted by another Adviser,
with the specific fees and services applicable to financial planning or consulting engagements detailed in the
Financial Planning and/or Consulting Services Agreement. Consumers are invoiced for these services, with all
payments for Financial Planning or Consulting Services processed through AdvicePay, an unaffiliated service
provider. If a consumer terminates an agreement before the plan or consultation is completed, any unearned
prepaid fees will be refunded upon the provision of written notice to HTK.

Retirement Plan Consulting Services (RPCS)

For Retirement Plan Consulting Services (RPCS), HTK charges a fee based on a percentage of assets held in the
retirement plan up to 1%, an hourly basis up to $500 per hour, or a negotiated flat rate. These fees for advice
and services provided to ERISA retirement plans are negotiable between HTK and the client, and HTK shares a
percentage of the RPCS fee with the Adviser based on their specific agreement. If fees are paid prior to the
delivery of services, the retirement plan is entitled to a prorated refund of any prepaid fees for services not
received upon the termination of the agreement among the client, HTK, and the Adviser. Further details
regarding RPCS fees and mandatory regulatory disclosures are provided in HTK’s Section 408(b)(2) Disclosure
Statement, as required by the Department of Labor.

Other Fees and Expenses

TPAM Compensation and Revenue Sharing

HTK may receive certain fees from TPAMs for conferences, events, and marketing support services. This
compensation presents a conflict of interest, as there is an incentive for HTK and its Advisers to recommend
these TPAMs to clients.

Additionally, HTK may enter into revenue share arrangements for direct assets under management with certain
TPAMs. Under these arrangements, HTK may be paid a percentage of the assets invested. This compensation is
in addition to other payments or fees payable under separate agreements. These arrangements may create a
conflict of interest, as HTK and its Advisers are incented to choose a TPAM that provides revenue sharing.

  HTK                                                                                            Page 8 of 23

Commissions and Product Sales

Advisers providing financial planning and/or consulting services may also receive compensation from HTK or its
affiliates in connection with the sale of recommended financial products.

   −    Securities Transactions: If a consumer implements a recommendation to purchase or sell securities
        through an HTK Adviser, HTK and the Adviser will receive commissions or other compensation. This
        creates a conflict of interest, as there is an incentive to recommend products based on compensation
        rather than solely on client needs.
   −    Client Choice: Clients are under no obligation to execute transactions through the Adviser and may utilize
        unaffiliated representatives.
    −   No Fee Offsets: HTK does not reduce its advisory fees to offset commissions or markups.
...

Item 7. Types of Clients

HTK primarily serves individuals, high-net-worth individuals, trusts, businesses, and charitable organizations, as
well as retirement assets of individuals and businesses. This includes:

    −   Individual Retirement Accounts (IRAs)
    −   IRC 403(b) and 457 programs
    −   Employer-sponsored ERISA plans
    −   Taxable Accounts

Account Eligibility
Clients may open both qualified and non-qualified accounts with HTK; however, not all investors and plans are
eligible to invest with HTK’s advisory services. Clients should consult with their Adviser or their employer to
determine asset eligibility and should refer to their applicable plan provider for more detailed information
regarding account minimums and other conditions.

  HTK                                                                                            Page 14 of 23

Account Minimums and Requirements

TPAM

Account minimums for TPAMs may vary depending on the specific platform manager or custodian. Clients should
refer to the respective TPAM disclosure brochure for detailed account requirements.

Financial Planning and Consulting Services

There are no account minimums or front-end requirements for clients who engage in the financial planning and/or
consulting services offered by HTK.

Retirement Plan Consulting Services (RPCS)

HTK RPCS services are available to clients who are trustees or other fiduciaries to retirement plans, including
401(k), 457(b), 403(b), and 401(a) plans.