Lawley Retirement Advisors LLC

ITEM 5: FEES AND COMPENSATION

  A. Retirement Plan Fees

      Prior to engaging LRA to provide advisory services, the client will be required to enter into
      a written Investment Advisory Agreement (“Agreement”) with LRA setting forth terms and
      conditions, including those fees under which LRA shall render its services. Such fees are
      subject to negotiation under certain circumstances and at the sole discretion of the firm.

      For 3(38) Services, LRA fees will typically range from 10-100 basis points, but can vary
      based on advisory services provided.

      LRA fees are subject to negotiation. For LRA affiliates, our advisory fee may be less than
      what is assessed to other LRA clients.

      LRA fees can vary based on advisory services to the plan and its participants, plan
      demographics and characteristics. The frequency and assessment of LRA fees is outlined
      within each client agreement. LRA may be compensated by ACH, check, on a monthly,
      quarterly, or bi-annual basis and is based on AUM or a fixed fee. LRA fees are reviewed and
      discussed with clients on an annual basis.

      1. Fees Based on a Percentage of Assets Under Management (“AUM”)

          Typically, LRA charges its management fee based on a percentage of the reported
          market value of client’s retirement plan, as calculated by the client’s custodian, as of the
          close of business on the last business day of the billing period. Pursuant to the signed
          Agreement, LRA may bill the client in arrears or in advance, with such fees being
          assessed on a periodic basis, which may occur monthly, quarterly, or semi-annually

Lawley Retirement Advisors, LLC
Form ADV Part 2A

          (the majority of LRA clients pay in arrears, and the billing terms and period are set forth
          in each client’s Agreement). The actual percentage charged for these fees is based upon
          various plan demographics and characteristics and will be indicated on the client’s
          Agreement after being agreed to by both LRA and the client.

          Generally, a minimum fee of $5,000 per year applies. The minimum fee level may be
          waived at the sole discretion of LRA. Lower fees for comparable services may be
          available from other sources. These fees may be negotiated by LRA under certain
          circumstances, and at the sole discretion of LRA.

          Should a client engage LRA for retirement plan consulting services in the middle of a
          billing period, the Firm’s fees will be prorated based on the number of days that LRA
          rendered its services during the billing period. In the event that LRA’s services are
          terminated during a billing period, the annual fee shall be prorated through the date of
          termination and any balance will be refunded to the client.

      2. Fees Based on a Fixed Fee

          LRA may, at its sole discretion, enter into Agreements with clients whereby its
          management fees are paid pursuant to a fixed flat-fee basis rather than a percentage of
          the client’s AUM. In these instances, our fixed fees typically range from $5,000 up to
          $50,000. We do have a minimum fixed fee of $5,000 annually; however, this fee
          level may be waived at the sole discretion of LRA.

  B. Individual Health Savings Account Fees

      LRA will charge an advisory fee based on assets under management for individuals with
      Health Savings Accounts. LRA fees are disclosed to each individual investor.

  C. Other Fees and Expenses

      Clients should understand that the fees described above are exclusive to LRA and do not
      include certain charges imposed by third parties such as custodial fees, execution costs,
      mutual fund fees and expenses, and fees charged by third party advisers. Client assets also
      may be subject to transaction fees, brokerage fees and commissions, retirement plan
      administration fees, 12b-1 fees, wire transfer and electronic fund fees, and other fees on
      brokerage accounts and securities transactions. For mutual funds and ETFs, you may be
      charged internal management fees, distribution fee and other expenses, which will be further
      described in the funds’ respective prospectuses.

      Notably, LRA will not receive any portion of these other fees and expenses.

      Clients should understand that all custodial fees and any other charges, fees incurred in
      connection with transactions for a client’s plan may be paid out of the assets in the account
      and are in addition to the advisory fees charged by LRA. Furthermore, LRA will not
      receive any portion of the fees or expenses charged by the client’s custodian. Please refer
      to Item 12 of this Brochure for additional important information about the brokerage and
      transactional practices of LRA.

Lawley Retirement Advisors, LLC
Form ADV Part 2A

  D. Important Considerations

      We are affiliated with Lawley, LLC through common control and ownership. Lawley, LLC
      wholly owns two other financial planning and wealth management firms known as (1) Sgroi
      Lawley Group, LLC (“Sgroi”) and (2) Georgetown Lawley Group, LLC (“Georgetown”).
      Persons providing investment advice on behalf of LRA may also be IARs with our affiliate
      Georgetown. In their capacity as IARs, these persons will receive asset-based fees that are
      separate and apart from the fees that we charge at LRA. Because revenue is derived from
      asset-based fees, this creates a conflict of interest. This conflict exists because IARs from
      Georgetown are incentivized to grow your account rather than solely based on your needs.
      Please refer to Item 4 (Advisory Business) for more detailed information regarding Sgroi
      and Georgetown.

      Certain representatives of LRA, in their individual capacities, are also registered
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ITEM 7: TYPES OF CLIENTS

LRA provides advisory services primarily to pension and profit-sharing plans, including 401(k)
plans, 403(b) plans, deferred compensation plans and other defined contribution and defined
benefit plans.

LRA reserves the right to accept or decline a potential client for any reason in its sole discretion.