Jack V Butterfield Investment Company

Fees and Compensation

Program fees are calculated as a percentage of the account value. Fees are payable in advance on a quarterly basis
and calculated based on custodian’s appraisal of the market value of the assets in the account as of the last
business day of the preceding quarter or alternative quarter as elected. This value is multiplied by the annual fee,
multiplied by the # of days in the next quarter divided by 365. Where permitted, Client may elect to be billed on an
alternative quarterly cycle. Fees are assessed on all assets under management, including securities, cash, and
money market fund, or Credit Interest Program balances. Fees are prorated for any billing period that is less than
a complete calendar quarter, and the fee may be adjusted proportionately based on the value of cash or securities
added to or withdrawn from the account between billing periods. If the contract is terminated before the end of
the billing period the client shall receive a pro-rated refund based on the number of days left in the period.

Client Level                  Investment Products                     Fee Estimate   Service Level
$0 - $500,000                 Cash and Money Markets                  1.50%               Phone Calls and/or
                              Mutual Funds                                           Annual Meeting per request
                                                                                          Retirement funding
                                                                                              sensitivity
$500,001 - $1,000,000         Cash and Money Markets                  1.25%               Phone Calls and/or
                              Equity Mutual Funds                                    Semi-Annual Meeting per request
                              First Trust UITs                                            Retirement funding
                              Annuities                                                       sensitivity
Over $1,000,000               Cash and Money Markets                  1.00%               Phone Calls and/or
                              Individual Bonds                                       Quarterly Meetings per request
                              Individual Stocks                                           Full financial plan
                              Equity Mutual Funds
                              First Trust UITs
                              Annuities

The Program fee may be negotiated between Jack V. Butterfield Investment Co. and the client and is set forth in the
Client Agreement. Generally, minimum initial account values will be required in accordance with Program
guidelines. Some clients may pay higher or lower fees depending on considerations such as the size of the client’s
account, the amount of time the client has had an account with Jack V. Butterfield Investment Co., the total amount
of business the client conducts through Jack V. Butterfield Investment Co., the types of securities and services
provided, and other relevant criteria.

The fee will be deducted from the clients account on a quarterly basis.

The Program fee includes compensation for:
        • an initial analysis of the client’s investment objectives and needs, with periodic re-evaluations, provided
        by Jack V. Butterfield Investment Co.;
        • consulting services as to an appropriate investment strategy and as to specific securities to implement the
        strategy, provided by Jack V. Butterfield Investment Co.;
        • investment advisory services rendered by Jack V. Butterfield Investment Co.;
        • Periodic meetings with investors.;
        • other account related services, including financial planning services

The Program fee does not cover and clients will be additionally responsible and charged for:
        • commissions, mark-ups, spreads and other transactional charges on securities transactions effected
        through or with brokers and dealers other than Jack V. Butterfield Investment Co.;
        • interest on debit account balances, where applicable;
        • the entire public offering price (including underwriting commissions or discounts) on securities purchased
        from an underwriter or dealer involved in a distribution of securities;
        • bid-ask spreads, odd lot differentials, exchange fees, transfer taxes and other fees required by law;
        • Individual Retirement Account (IRA) fees, qualified retirement plan account fees and other account
        maintenance fees, where applicable;
        • redemption fees imposed by certain mutual funds (see the fund prospectus for details);
        • any contingent deferred sales charge assessed on the sale or liquidation of mutual fund shares, where
        applicable;
        • management and other fees on open-end and closed-end mutual funds and UITs;
        • margin interest;
        • short-term trading charges for purchases and corresponding redemptions of certain mutual fund shares
        (see fund prospectus for details) made within short periods of time. These short-term trading charges are
        imposed by the mutual funds to deter “market timers” who trade in fund shares;
        • safe keeping fees for physical securities; and
        • Excess trade fees

Program fees cover only the services provided under the Program Agreement. Certain investment products, such
as closed-end funds, unit investment trusts or exchange-traded products may incur management and operating
expenses that are not covered by the Program fees. Please refer to each investment products disclosure document
for a more detailed description of the fees and expenses you may pay as an investor. Each mutual fund pays
separate management fees and other fees and expenses as detailed in the prospectus provided to the client. Some
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Types of Clients

Our clients include individuals, trusts, and pension/401k plans. The minimum account value needed to open an
advisory account is $25,000. Our clients are categorized as high net-worth if the account value totals $1,500,000 for
individuals and $3,000,000 for joint accounts.

Methods of Analysis, Investment Strategies and Risk of Loss

Jack V. Butterfield Investment Co. requires the client complete a Risk Profile Questionnaire, which is intended to
measure the client’s investment objectives, time horizon and risk parameters. The client is responsible for promptly
bringing to Jack V. Butterfield Investment Co’s attention any material change in the client’s investment objectives or
financial condition. Based on this information (and any additional written investment guidelines the client
establishes) and the consultation process, the FC recommends an appropriate investment strategy to the client. If
the strategy includes an asset allocation it may also include a fund allocation - that is, an assignment of a
percentage of the overall value of the account to one or more mutual funds.

The FC may recommend eligible securities, including mutual funds, offered at their net asset value without any
front-end or deferred sales charge, which may also include no-load funds, that Jack V. Butterfield Investment Co.
believes possess investment characteristics that are consistent with the client’s investment objectives and needs.
 If the strategy will be implemented with mutual funds only, the client selects from the various eligible mutual funds
and specifies, in writing, the mutual funds in which account assets are to be invested and the allocation among
those funds. This written fund allocation may subsequently be modified by the client by notifying the Jack V.
Butterfield Investment Co of the client’s changes.

Jack V. Butterfield does not have discretionary authority with respect to the Program account. The client has sole
discretion whether to accept or reject an investment strategy or any specific recommendation to purchase, sell, or
redeem securities. The client receives investment advice from Jack V. Butterfield Investment Co. and Jack V.
Butterfield Investment Co.’s Financial Consultant.

Portfolio Strategy and Asset Allocation - At Jack V. Butterfield Investment Co, we construct your portfolio by
incorporating a diversified mix of asset types tailored to your long-term financial goals. When appropriate, we may
include high-quality, short-duration bonds to help lower the overall volatility of your portfolio, produce more

consistent income through interest payments, support periodic rebalancing efforts, and serve as a potential buffer
against inflation.

If your investment goal is to achieve higher expected returns and you're comfortable with increased market risk, we
may recommend a portfolio with a heavier weighting in equities—particularly in small-cap and value-oriented
stocks. These allocations are typically implemented using broad-based index funds or asset class mutual funds.
Stock investments will usually be diversified across both U.S. and international developed markets, and where
suitable, small allocations to emerging markets and real estate investment trusts (REITs) may be included.
Importantly, our asset allocation strategy is grounded in your long-term objectives, not influenced by short-term
market fluctuations. We only adjust the allocation if your goals or circumstances materially change.

Our approach is built on the understanding that different types of investments perform differently depending on
market and economic cycles. Because future performance of any single asset class is difficult to predict,
diversification serves as a key risk management tool. However, diversification does not guarantee profits or protect
against losses in down markets. It also means that not every asset will outperform in every market, and as such,
maximum returns are not the primary goal.

Ongoing Portfolio Rebalancing - As market conditions change, the relative weight of each asset class in your
portfolio may drift from the original targets. When this happens, we take a disciplined approach to rebalancing by
trimming asset classes that have grown beyond preset thresholds and reallocating funds into areas that have
declined. This strategy allows us to systematically buy lower and sell higher—without relying on market timing or
forecasting.

Our rebalancing practices are designed to support long-term performance while keeping the portfolio aligned with
your risk tolerance. To minimize trading costs and unnecessary transactions, we follow established rebalancing
ranges. Adjustments are only made when allocations move outside those set parameters.

Investment Selection Process - Jack V. Butterfield Investment Co typically uses mutual funds, ETFs, or similar
pooled investment vehicles to build portfolios. However, when appropriate, we may also incorporate individual
stocks or bonds. In these cases, we conduct a thorough review of each security’s management team, financial
health, and market position to ensure alignment with your investment objectives, time horizon, and risk profile.

Individual stock investments carry unique risks, including price fluctuations due to company-specific issues,
economic trends, regulatory changes, or industry-specific events. Similarly, individual bonds are exposed to risks
such as interest rate changes, issuer creditworthiness, and liquidity constraints, which could affect the bond’s price
and income-generating ability.

Investment Risk and Loss Considerations - All investments carry inherent risks, including the possibility of losing
some or all of the invested capital. Clients should be aware that investing involves uncertainty, and no outcome is
guaranteed. Investing in securities involves risk of loss that clients should be prepared to bear. As demonstrated by
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