Janney Capital Management LLC

ITEM 5 - FEES AND COMPENSATION
Janney and Janney Capital have entered into an agreement under which Janney Capital agrees to manage the assets
of client accounts in the Programs. As part of that agreement, Janney Capital and Janney agree on the investment
advisory fees to be charged by Janney Capital on those assets. The fees charged by Janney Capital on assets of a
client who chooses to participate in a Program advised by Janney Capital typically range from 0.10% to 0.50% per
year based on the value of the assets in the client’s account. The fees are included in the fee charged by Janney to
the client quarterly in advance, based on the market value of the client’s assets on the last business day of the
quarter. Janney remits payment of the fees to Janney Capital.

In the event the account is terminated, the investment advisory fee is prorated through the effective date of
termination, as defined by the investment advisory agreement, and any remaining balance shall be refunded to
the client. Generally, cash and cash equivalents are considered billable assets and are included in the calculation
of the investment advisory fee. If a client does not custody assets at Janney, an invoice is sent to the client for
payment of the fee.

Janney clients who select Programs advised by Janney Capital, including the ETF Advantage, Keystone
Discretionary, and Janney Capital Management Direct Programs offered by Janney, typically do so under a single
investment advisory agreement with Janney, which contains the terms described above.

Janney Capital also receives a fee from each program sponsor to which we provide UMA model portfolios. Fees
generally range from 0.10% to 0.50% per year based upon the program sponsor’s underlying assets managed to
each model portfolio strategy.

Brokerage and Other Transaction Costs
In addition to Janney Capital’s advisory fees, clients may incur additional brokerage and other transaction costs in
connection with securities transactions that Janney Capital engages in for their accounts. Such costs include
brokerage commissions, commission equivalents, odd-lot differentials, exchange fees, SEC fees, transfer taxes,
stamp taxes and other transaction costs.

 JANNEY CAPITAL MANAGEMENT                                                                               PAGE - 13

These additional fees or expenses can be part of transaction fees for certain products, such as the purchase or sale
of ADRs through a third-party financial institution. Client’s cost will be reflected as either a mark-up or mark-down
(depending upon whether the transaction is a purchase or sale) in the price per ADR shares or in a separate
commission or charge. In addition, investments in mutual funds and ETPs will result in the layering of expenses,
resulting in a higher cost of investment than the cost of investing directly with a mutual fund or ETP.

From time to time, Janney Capital may purchase fixed income for one of its strategies for which Janney served as
underwriter in a competitive bid municipal offering. Because of the compensation Janney receives in the form of
underwritings fees, Janney Capital may have an economic interest in purchasing the offering. While Janney Capital
makes securities recommendations based on the best interests of its clients in fulfillment of its fiduciary obligations,
it is standard practice that Janney Capital makes every effort to avoid the conflicted offerings whenever possible.
Should those circumstances occur, Janney Capital will designate the underwriting fees to another dealer in the
offering to ensure that Janney does not receive conflicted compensation from the offering.

Other Fees and Expenses
In addition to Janney Capital’s advisory fees and brokerage and other transaction costs, clients may pay other fees
and expenses in connection with Janney Capital’s advisory services, such as custodian fees to their custodians, wire
transfer and electronic fund fees, margin interest fees, and other charges, taxes or fees mandated by any federal,
state or applicable law. Additional fees may also apply to clients in certain advisory programs that opt out of
electronic delivery and choose instead to receive paper statements.

Accounts that hold shares of mutual funds (including money market funds), CEFs, ETFs, or other investment
companies or investment pools (collectively, “funds”) include the value of these assets when calculating the
applicable advisory account fees. In addition to account fees and expenses, client assets invested in funds are
subject to other fees and expenses as described in the funds’ prospectuses or offering documents, including the
management fee and other fees and charges payable by the fund. As a result, clients bear indirectly a portion of
any investment management and other fees (such as dealer concessions, administration, custody, transfer agency,
legal, audit, transaction-related and distribution) paid by a fund in addition to any account fees.

In addition, certain funds in which client assets are invested trade securities through an affiliate’s institutional
brokerage group (Janney), including both fixed income and equity securities. As a result, Janney receives a benefit
from such trades in either the commission paid for agency trades or the mark-up for principal trades. Janney
Capital’s policy is to not recommend or use discretion to place investment advisory client assets in these funds
simply because the managers for such funds may execute trades through an affiliate. In addition, funds typically
have their own policies prohibiting the fund’s manager from executing trades with a brokerage firm based on the
amount of assets that firm’s clients have invested in such fund.

Janney Capital has a financial conflict of interest when managing a wrap fee account with little or no turnover,
because Janney Capital still earns a wrap fee on such account which would have included any costs associated with
trading in the account.
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ITEM 7 - TYPES OF CLIENTS
Janney Capital offers investment advisory services to a broad range of Janney clients through Janney’s wrap
Programs. Janney’s clients consist of individual and institutional clients including, but not limited to, individuals
(including high net worth), families, trusts, estates, corporate and non-corporate entities, retirement plans,
pension plans, profit-sharing plans, charitable and religious organizations, and government entities. Janney Capital
also provides investment advisory services to unified management accounts.

Minimum Investment Amounts
The minimum investment for a separately managed account with Janney Capital is generally $100,000, with the
exception of separately managed account(s) in the Short Duration Income strategy which has an investment
minimum of $250,000. The minimum investment amount for the Janney Capital strategies managed for Janney
Program accounts range from $25,000 to $100,000. Details on those Programs and the minimums for each Program
can be found in Janney’s Form ADV Part 2A Investment Management Disclosure Brochure.