Janney Montgomery Scott LLC

ITEM 5 - FEES AND COMPENSATION
Janney is typically compensated for investment advisory services by charging a fee based on a percentage
of the assets under management in the Client account. With respect to the Programs, the asset-based
investment advisory fee typically includes fees, charges and expenses associated with investment
management, trading and execution, custodial services and performance reporting. Under limited
instances, a wrap-fee Client may maintain assets with a third-party custodian. In that case, a Client would
pay the third-party custodian separately for custodial services.

In general, fees may be negotiated with the Client’s Financial Advisor and may differ from the fee schedule
set forth in this Brochure, based upon a number of factors, including, but not limited to, the size of the
Client’s account, other related accounts at Janney, the projected nature of trading in the Client’s account,
and the extent of services to be provided by Janney to the Client’s account. In limited circumstances, a
Client may request a flat fee arrangement, where Janney charges a mutually agreed upon fixed annual fee
assessed quarterly, which will be subject to the review and acceptance by Janney’s Wealth Management
Department. Clients that select the investment strategies managed by JCM, Janney’s professional asset
management division, available in the Janney Capital Management Direct Program, Keystone Program,
ETF Advantage Program, and Janney UMA program, are charged an active asset management fee. When
utilizing multiple investment strategies or sleeves in a single JCM Direct account, Janney does not utilize
a weight-blended advisory fee but rather, will apply the highest advisory fee of the selected investment
strategies to the entire account.

Janney may provide, at its sole discretion, investment advisory services on a non-wrap basis where the
Client pays a fee for investment advisory services only and pays separately for transaction and custody
costs related to such investments. This type of fee arrangement may not be available to certain types of
accounts (e.g., retirement accounts). Clients could pay greater overall fees in a commission-based account
or a commission plus fee account than a wrap fee account and vice versa depending on the level of trading
and other factors. For example, if there is little or no trading activity in the account, it is possible for a
Client to pay more in advisory fees than commission charges if the account was a brokerage account.

Calculation of Advisory Fees
Janney’s advisory fees are typically billed quarterly in advance, except as specifically noted below. The
initial fee, and when applicable the active asset management fee and/or Third-Party Manager fee, , is
charged on the date such assets are accepted for management and calculated on a pro-rata basis based
on the days remaining in the calendar quarter. Thereafter, Janney calculates the fee at an annual rate
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based upon the market value of the Client’s account as of the last business day of the calendar quarter
(i.e., March 31st, June 30th, September 30th and December 31st). Fees will be refunded if the account is
terminated in writing by Janney or the Client for the pro-rata portion of the quarter for which no advisory
services were provided.

In computing the asset value of the Advisory Accounts held at Janney, the firm generally relies on pricing
available from securities exchanges, third-party pricing sources, issuers, sponsors and other custodians.
Advisory Account Assets traded on a national securities exchange or quoted on an automated quotation
system are valued at the last sale price on the exchange or automated quotation system, or, if there has
been no sale that day, at the last known bid price. Advisory Account Assets that are traded over-the-
counter are valued according to the broadest and most representative market and valued at the known
current bid price Janney believes most closely represents the current market value.

Mutual fund shares are valued at their net asset value on the valuation date as described in the funds’
prospectuses. For mutual fund shares held away from Janney like those in 529 savings plans, Janney
utilizes the most recent value reported to us by the 529 savings plan. The value of held away mutual funds
is reported to Janney on a delay, which means that the value utilized by Janney to calculate your advisory
fee may be more or less than the net asset value of the fund on the billing date. Additional deposits
received intra-quarter will not be subject to a pro-rated fee for the remaining days of the quarter. Instead,
the additional funds will be included in the account value during the next quarterly billing cycle.

For privately offered securities, Janney utilizes the most recent position value reported to us by each fund
administrator. The value of privately offered securities is reported to Janney periodically and the timing
of such reporting may vary between fund administrators. This means that the value utilized by Janney to
calculate your advisory fee may be more or less than the net asset value of each fund on the billing date.
Any other securities or investments in the Advisory Account are valued in a manner that Janney
determines in good faith to reflect fair market value on the date of valuation. Janney relies, without
verification, on valuations furnished by an independent party Janney selects that it believes to be reliable.

These good faith valuations may vary between other independent parties and other factors not assessed
may substantially affect the valuation(s). Therefore, valuations may reflect a higher or lower fair market
value depending on the independent party selected and relied upon. There are no assurances that (i)
...

ITEM 7 - TYPES OF CLIENTS
Janney offers investment advisory services to a broad range of individual and institutional Clients
including, but not limited to, individuals, families, trusts, estates, corporate and non-corporate entities,
retirement plans, pension plans, profit-sharing plans, and government entities. In most cases, Janney
requires a minimum initial investment to open a Program account which varies depending on the
Program.

The following chart sets forth the initial minimum investment by Program.

                                                                     Minimum
                                       Program                         Initial
                                                                    Investment
                                  Professional Money Management
                        Adviser’s                            $100,000*
                        Janney UMA                           $50,000*
                        Classic                              $100,000*
                        Janney Capital Management Direct     $100,000*

                                            Asset Allocation
                        Keystone Discretionary                        $25,000
                        ETF Advantage                                 $25,000
                        Goals-Based Portfolio Solutions (GPS)
                        Program                                       $5,000
                        Pioneer                                       Varies*

                                     Internal Portfolio Management
                        Partners**                                    $10,000
                        Compass                                       $25,000
                        Investors Select                              $25,000

*The initial minimum investment amount required for select strategies in the Adviser’s, Janney UMA,
Janney Capital Management Direct, Pioneer and Classic Programs may be higher or lower than the
Program minimums required by Janney. For example, the minimum investment for a Janney Capital
Management Direct account is generally $100,000, with the exception of account(s) in the Short Duration
Income strategy which has an investment minimum of $250,000. Janney may waive, in its sole discretion,
the initial minimum investment required by Janney for an account. In determining whether to waive an
investment minimum, Janney considers the following factors: household asset value, investment vehicles
and the anticipation of upcoming contributions and/or necessary withdrawals in the account. A Third-
Party Manager may have a higher minimum investment depending on the strategy selected. Janney UMA
accounts must meet the minimums for each sleeve of the account.

** A minimum investment amount of $1,000 will be applied to Advisory 529 savings plans when held in
the Partners Program.

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 JANNEY MONTGOMERY SCOTT LLC                                                                      PAGE - 33