Hurley Financial Group Inc

Item 5. Fees and Compensation

We offer our advisory fee program only through Schwab Advisor Services™ (SAS) platform. (Approximately
96% of Advisory Billing). Your assets will be maintained in an account at Charles Schwab &Co., Inc.
(Schwab).

The SAS program is offered on a discretionary trading basis for continuous portfolio management.

In an account with discretionary trading, the IAR may purchase or sell load-waived mutual funds, no-load
mutual funds and other equity and debt securities for accounts not included in the initial asset allocation,
without obtaining specific client approval for each transaction.

In addition, SAS provides the following comprehensive investment consulting services:
         •       Review of investor’s current financial situation and analysis of future financial goals
         •       Review of investor’s current investments and design and implementation of appropriate
                 investments based on the nature of client’s other assets, family obligations and personal
                 needs
         •       Year-long, continual monitoring of investments
         •       In-depth meetings: to review and evaluate investor’s investment performance, update overall
                 financial objectives, and reallocate investor’s portfolio, as necessary
         •       Commission-free transactions on most stocks, bonds or mutual funds traded in investor’s
                 account
         •       Recommendations regarding positioning of funds within investor’s employer provided
                 retirement plans such as 401(k)s
         •       Quarterly letters detailing the firm’s research, analysis and view of the current state of the
                 investment markets
         •       Advice on other areas including, but not limited to, tax reduction, estate planning,
                 retirement income and charitable giving strategies

Ongoing advisory fees for the SAS program are calculated using a banded fee schedule for assets under
management. For clients with multiple portfolios in the SAS program, the fee schedule will be aggregated
based on the total size of all portfolios per client household. Certain holdings may be excluded from billing,
for example, individual stock holdings held as a courtesy for the client. Clients may be charged a maximum
of 1.60% annually. However, the actual fee schedule is set forth in the Schwab Investment Advisory
Agreement which is signed by the client prior to or concurrent with their engagement into the program.

HFG maximum fee schedule is listed in the table below.

                           Portfolio Value               Annual Fee Schedule
                           $0 - $1 M                           1.60%
                           $1 M - $2 M                         1.00%
                           $2 M - $5 M                         0.80%
                           $5 M and over                       0.60%

The fee percentages listed above are annual fees. For example, a portfolio valued at $500,000 at the end of
a quarter would be billed at 0.40% or ($2,000). The charges to the account are on an arrears basis and are
remitted quarterly. The advisory fee is debited from the client’s account by Schwab on behalf of HFG.
Schwab does not participate in the Advisory fee. This fee is forwarded directly to HFG. HFG then forwards a
fee to Geneos Wealth Management, Inc. (“GWM”), for the functions GWM is required to carry out by FINRA,
Financial Industry Regulatory Authority.

Hurley Financial Group, Inc.                   ADV Part 2A                    Rev Date: March 1, 2026

The advisory fee is subject to negotiation and may be higher or lower than the cost of similar services offered
through other financial firms. The advisory fees shall continue until thirty (30) days after IAR has notified
client in writing of any change in the amount of the advisory fee. At such time, the new advisory fee will
become effective unless client notifies IAR in writing that the account is to be closed.

Tamarac & Schwab Fees. As compensation for HFG’s cost of trading and reporting services through the
Tamarac system, HFG will charge a platform fee of 0.10% per annum (.0025%) per quarter in arrears for
assets under management. Schwab generally will not charge you separately for custody services,
commissions or transaction fees. Schwab will be compensated by earning interest on the uninvested cash in
your account in Schwab‘s Cash Features Program. See Item 12. Brokerage Practices, for more details.

Upon written notification, the agreement may be terminated by either HFG or the investor. Prorated fees will
be charged based on market value on the date the termination notice is received.

Clients sign an advisory fee contract with the IAR and account opening paperwork with Schwab. IAR
provides to the client: HFG Form ADV, Form CRS and prospectuses are available on-line at the respective fund
companies. Clients may request to receive all prospectuses in hard copy via regular mail. Clients also have
the option to have the IAR receive all proxy materials and other security information.

HFG may provide investment advice through financial planning consultations (Less than 1% of total Advisory
billing):

Hurley Financial Group, Inc. may receive fees for developing a detailed written financial plan or for providing
consulting services for a client. Applicant will either be charged an hourly fee of between $150.00/hour and
$250.00/hour or a flat fee of between $250.00 and $1,500.00. This specific fee will be communicated to the
client and agreed to by the client prior to the commencement of work, through a signed Financial Planning
Agreement. No financial planning fees are prepaid. Fees are due at the completion of the project or billed
monthly for consulting services. The financial planning fee may be waived at IAR’s discretion.
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Item 7. Types of Clients

Hurley Financial Group, Inc. clients are primarily high net worth individuals and families at or nearing
retirement. HFG has a defined household Investable Asset Minimum (IAM) of $250,000. IAR may have lower
minimums and the minimum household account size may be waived at the IAR’s discretion. If a prospective
client does not meet the IAM and wishes to become a client of Hurley Financial Group, Inc., IAR may charge a
flat planning fee of $500.00 per quarter in addition to any investment management service fees or product
commissions, where applicable. This planning fee is reviewed at every annual client meeting and adjusted or
moved as the client’s assets approach and meet the IAM.