JNBA Financial Advisors LLC

Item 5           Fees and Compensation

   A.
                                   INVESTMENT ADVISORY SERVICES
         The Registrant’s annual investment advisory fee shall be based upon a percentage (%) of
         the market value and type of assets placed under the Registrant’s management, accrued
         interest on bonds and dividends payable on mutual funds (between 0.65% and 1.00%) as
         follows:
                              Market Value of Portfolio          % of Assets
                              $1,000,000 - $3,000,000            1.00%
                              $3,000,001 - $5,000,000            0.85%
                              $5,000,001 - $10,000,000           0.75%
                              Over $10,000,000                   0.65%
         *Registrant, in its sole discretion, may provide investment advisory services to a client
         with less than $1,000,000 in assets under management for a minimum annual flat fee of
         $10,000. In such instances, the minimum annual fee of $10,000 will be billed quarterly,
         until such time as the client’s assets reach $1,000,000. Clients with less than $1,000,000
         in assets under management will therefore pay a higher percentage fee than if it placed
         $1,000,000 under Registrant’s management.

         ** The Registrant’s investment advisory fee is negotiable at its discretion, depending
         upon objective and subjective factors including but not limited to: the amount of assets to
         be managed; portfolio composition; the scope and complexity of the engagement; the
         anticipated number of meetings and servicing needs; related accounts; future earning
         capacity; anticipated future additional assets; the professional(s) rendering the service(s);
         prior relationships with the Registrant and/or its representatives, and negotiations with the
         client. As a result of these factors, similarly situated clients could pay different fees, the
         services to be provided by the Registrant to any particular client could be available from
         other advisers at lower fees, and certain clients may have fees different than those
         specifically set forth above.

         Custodial Statement Valuation. Client’s custodial statements will generally not account
         for any accrued interest on bonds or dividends payable on mutual funds until one or two
         days into the following quarter. Additionally, deposits to or withdrawals from a client’s
         account on the last billing day of the month may not be reflected on custodian’s current
         statement. These transactions will appear in the following statement reflecting the actual
         and accurate date of the deposit or withdrawal. Therefore, in some instances, what the
         Registrant uses as the client’s quarter end balance may be different from what the client’s
         custodial statements reflects as an ending balance.

                FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
         Registrant’s planning and consulting fees are negotiable, but generally range from $1,500
         to $10,000 on a fixed fee basis, and from $125 to $250 on an hourly rate basis, depending
         upon the level and scope of the service(s) required and the professional(s) rendering the
         service(s).

                              RETIREMENT PLAN CONSULTING
   The Registrant may also be engaged to provide investment recommendations to
   employee profit sharing and 401k plans pursuant to ERISA Section 404(c). The
   Registrant’s fee schedule for these engagements is as follows:

                       Market Value of Plan Assets            % of Assets
                       First $2,500,000                       0.50%
                       $2,500,001 - $5,000,000                0.25%
                       $5,000,001 - $10,000,000               0.15%
                       Over $10,000,000                       0.10%

                                       FAMILY OFFICES
   The specific manner in which our family office clients are charged fees is established in a
   written agreement between each client and Registrant. Fees may differ from the fees in
   the schedules disclosed above, and each family office will be subject to distinct fee
   structures based upon certain factors. Registrant may, in its sole discretion, charge a fee
   based upon the level of service, the level of complexity involved, the expertise of the
   adviser providing the services, anticipated future earning capacity, anticipated future
   additional assets, dollar amount of assets to be managed, related accounts, account
   composition, complexity of the engagement, anticipated services to be rendered and the
   number of hours spent providing services to the client, grandfathered fee schedules,
   employees and family members, courtesy accounts, competition, and negotiations with
   client.

B. Clients may elect to have the Registrant’s advisory fees deducted from their custodial
   account. Both Registrant's Investment Advisory Agreement and the custodial/clearing
   agreement may authorize the custodian to debit the account for the amount of the
   Registrant's investment advisory fee and to directly remit that management fee to the
   Registrant in compliance with regulatory procedures.

   In the limited event that the Registrant bills the client directly, payment is due upon
   receipt of the Registrant’s invoice. The Registrant shall deduct fees and/or bill clients
   quarterly in advance, based upon the market value of the assets on the last business day
   of the previous quarter.

C. As discussed below, unless the client directs otherwise or an individual client’s
   circumstances require, the Registrant shall generally recommend that Charles Schwab &
   Co. Inc. (“Schwab”) serve as the broker-dealer/custodian for client investment
   management assets.
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Item 7           Types of Clients

         The Registrant’s clients shall generally include individuals, pension and profit sharing
         plans, business entities, trusts, estates and charitable organizations.