Kraft Davis & Associates LLC

Item 5 – Fees & Compensation
                                  Asset Management/ADK Wealth Wrap Fee Program

The specific way fees are charged by the firm is established in a Client’s written Consulting Agreement and account
application between the Client and ADK – up to 2.5% of assets under management. Clients can determine to engage the
services of ADK on a discretionary or non-discretionary basis. For Clients opting to receive non-discretionary services,
ADK will secure Client’s authorization prior to executing transactions. The firm’s annual investment advisory fee
(“Account Fee”) shall be based upon a percentage (%) of the market value and type of assets placed under the firm’s
management to be charged quarterly in advance, and ADK IARs may at their discretion negotiate a fee. Fees may vary due
to complexity of management, allocation, or other variables. Individual IARs may have varying fee structures compared to
other IARs within the firm for comparable services. IAR’s may exercise discretion in determining the advisory fees assessed
to their clients, provided such decisions remain within the guidelines of the firm.

The Account Fee charged to the Client for each advisory program is subject to the following maximum account fees:

                 Advisory Program                          Annual Percentage of Assets Charge
                 SWM II & OMP                                           2.5%
                 PWP                                                     2.5%
                 MWP                                                     2.5%
                 Manager Select                                          2.5%

LPL is responsible for calculating and deducting advisory fees from Client accounts. Clients must provide LPL with written
authorization to deduct fees from their account and pay the advisory fees to ADK. Clients also can pay their advisory fees
by check. ADK will then share the advisory fee with its IARs.

In addition to the advisory fee, Clients who do not participate in a wrap fee program (SWMI) will pay all transaction charges
for trade execution. ADK will not receive any portion of the transaction charges. These transaction charges are outlined in
the LPL brokerage account application and are paid to LPL. If the custom advisory services apply to variable annuities for
which the IAR receives trail compensation, such trail fees generally will be used to offset the advisory fee. In most cases,
however, a third-party broker-dealer will provide trade execution. In such case, the broker-dealer may charge Clients
commissions, markups, markdowns and/or transaction charges. For Client’s who participate in a wrap fee program, either
sponsored by ADK or LPL, they will pay some costs for miscellaneous services. For example, check printing fees, overnight
delivery fees, etc.

In connection with investments made through the account, the Client may also incur certain charges imposed by third-
parties other than ADK including, but not limited to, mutual fund 12b-1 fees, mutual fund management fees and
administrative expenses, mutual fund transaction fees, deferred sales charges on previously purchased mutual funds
transferred into the account, variable annuity expenses, other transaction charges and service fees, IRA and qualified
retirement plan fees, administrative servicing fees for trust accounts, creation and development fees or similar fees imposed
by unit investment trust sponsors, hedge fund and managed future investment management fees, managed futures investor
servicing fees, fees relating to American Depository Receipts, and other charges required by law.

Either party may terminate the agreement for services at any time. If the Account Agreement is terminated before the end
of the quarterly period, the Client is entitled to a pro-rated refund of any pre-paid quarterly advisory fee based on the number
of days remaining in the quarter after the termination date. For additional information, please see Item 12 – Brokerage
Practices.

                                       Personal Wealth Portfolios Program (PWP)

In the PWP program, Clients pay LPL and its IARs a single wrap fee (“Account Fee”) for advisory services and execution
of transactions. The Account Fee is negotiable between the Client and the IAR and is set out in the Client Consulting
Agreement. The Account Fee is a straight percentage based on the value of all assets in the account, including cash holdings.
The maximum Account Fee will not exceed industry standards and is 2.50%. The Account Fee is paid to LPL, and LPL
retains 0.10% for its Overlay Portfolio Manager services, and up to 0.58% for its administrative, custody and clearing
services and the Portfolio design services of LPL Research. LPL pays a portion of the Account Fee to the PWP Advisors.

LPL shares between 90% to 100% of the remaining portion of the Account Fee with the IAR based on the agreement
between LPL and the IAR. The portion of the Account Fee paid to the PWP Advisors varies by asset class and investment
strategy, and ranges from 0.15% to 0.35%. To the extent that fee rates charged by PWP Advisors within the same asset class
vary, an IAR may have a financial incentive to select one PWP Advisor over another. If a Portfolio is selected that does
not include a PWP Advisor Model, this will result in each of LPL and the IAR retaining a greater portion of the Account
Fee than if a Portfolio was selected that included a PWP Advisor Model, because no portion of the Account Fee will be paid
to a PWP Advisor.

The fees paid by LPL to PWP Advisors in the program are generally less than a PWP Advisor would charge a Client seeking
to establish a direct relationship outside of the program. LPL is absorbing many of the billing, administrative, and marketing
expenses that would otherwise be borne by the PWP Advisor and the role of the PWP Advisor is generally limited to
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Item 7 – Types of Clients
The advisory services offered by ADK are available for individuals, individual retirement accounts (“IRAs”), banks and
thrift institutions, pension and profit-sharing plans, including plans subject to Employee Retirement Income Security Act of
1974 (“ERISA”), trusts, estates, charitable organizations, state and municipal government entities, corporations and other
business entities.

For LPL’s Financial-Sponsored Advisory Programs account minimums are as follows.

        •    Asset Management (Strategic Wealth Management Platform (SWM): $0
        •    Personal Wealth Portfolios Program (PWP): $250,000
        •    Model Wealth Portfolios Program (MWP): $25,000
        •    Manager Select Program (MS): $100,000
        •    Optimum Market Portfolio (OMP): $10,000

For customized advisory services, any required minimum account value will be set out in the Client agreement. The
minimum account size depends on the services offered and may be waived at ADK’s discretion.