Liberty One Investment Management LLC

Fees and Compensation - Item 5

 Portfolio Management Services Fees
 For portfolio management services, Liberty One charges an annual fee of up to 0.65% of total account value. Fees
 are payable monthly or quarterly, in advance or in arrears, and are based on the value of assets on the last day of
 the relevant pay period. Where the fee is payable in advance, fees will be pro-rated for the first partial month or
 quarter. Portfolio management fees are negotiable depending on factors such as the amount of assets under
 management, range of investments, and complexity of the client’s financial circumstances, among others. The
 agreed upon fee to be paid by the client will be clearly stated in an Advisory Agreement signed by the client and
 the firm.

 As described above in Item 4, our model portfolios holding ETFs managed by us will not pay a separate
 management fee. Instead, we derive our compensation for the management of such model portfolios from the
 expense ratio charged by the ETF(s) that we manage that is/are held in the model portfolio.

 Liberty One provides direct portfolio management services to clients with a minimum account size of $5,000,000.
 For portfolio management services given through financial intermediaries, Liberty One generally requires a
 minimum account size of $50,000 to open and manage an advisory account. However, Liberty One may from time
 to time in its discretion accept smaller accounts based on various criteria, such as anticipated future assets,
 related accounts, and other factors.

 Generally, the custodian holding the client’s account will deduct Liberty One’s fees and any other custodial fees
 directly from a designated account to facilitate billing, provided the client has given written authorization. The
 qualified custodian will send an account statement at least quarterly. This statement will detail all account activity.
 Fees are usually deducted from a single designated client account to facilitate billing. In limited circumstances, at
 the sole discretion of Liberty One, we may agree to invoice you directly for our advisory fee or we may negotiate
 other fee payment arrangements. Where we provide portfolio management services through financial
 intermediaries, the fee is deducted by the various financial institutions and forwarded to us.

 Our annual fee is exclusive of, and in addition to brokerage commissions, transaction fees, and other related costs
 and expenses which will be incurred by the client. However, we will not receive any portion of the commissions,
 fees, and costs. Please see Item 12 – Brokerage Practices for further information on brokerage and transaction
 costs.

 You may terminate the portfolio management services agreement upon 30-days’ written notice to our firm. You
 will incur a pro rata charge for services rendered prior to the termination of the Advisory Agreement, which means
 you will incur advisory fees only in proportion to the number of days in the pay period for which you are a client.
 If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees.

 Additional Fees and Expenses
 The fees Liberty One charges are negotiable based on the amount of assets under management, complexity of
 client goals and objectives, and level of services rendered. As described above, the fees are charged as described
 and are not based on a share of capital gains of the funds of any advisory client.

 All fees paid to Liberty One for investment advisory services are separate and distinct from the fees and expenses
 charged to shareholders by mutual funds or exchange traded funds. These fees and expenses are described in

Liberty One Investment Management, LLC
Form ADV Part 2A

 each fund's prospectus. These fees generally include a management fee, other fund expenses, and a possible
 distribution fee. If the fund also imposes sales charges, you may pay an initial or deferred sales charge.

 You could invest in a mutual fund directly, without the services of Liberty One. In which case, you would not
 receive the services provided by Liberty One, which are designed, among other things, to assist you in determining
 which mutual fund or funds are most appropriate to your financial condition and objectives. Accordingly, you
 should review both the fees charged by the funds and the fees charged by Liberty One to fully understand the
 total amount of fees to be paid by you to evaluate the advisory services being provided.

 Billing on Cash Positions: The firm treats cash and cash equivalents as an asset class. Accordingly, unless
 otherwise agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included
 as part of assets under management for purposes of calculating the firm’s advisory fee. At any specific point in
 time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such
 anticipated market conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for
 defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts
 could miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could
 exceed the interest paid by the client’s cash or cash equivalent positions.

 Periods of Portfolio Inactivity: The firm has a fiduciary duty to provide services consistent with the client’s best
 interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to
 determine if any changes are necessary based upon various factors, including but not limited to investment
 performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial
 circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may
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Types of Clients - Item 7

 We generally offer our investment advisory services to high-net-worth individuals. We also act as a sub-adviser,
 wrap program manager or portfolio model provider to investment advisers, broker dealers and other financial
 institutions. We are also the appointed investment adviser to several exchange-traded funds.

 Liberty One provides direct portfolio management services to clients with a minimum account size of $5,000,000.

Liberty One Investment Management, LLC
Form ADV Part 2A

 For portfolio management services given through financial intermediaries, Liberty One generally requires a
 minimum account size of $50,000 to open and manage an advisory account. However, Liberty One may from time
 to time in its discretion accept smaller accounts based on various criteria, such as anticipated future assets,
 related accounts, and other factors.

                       Methods of Analysis, Investment Strategies and Risk of Loss - Item 8

 Liberty One advisors will use various methods to determine an appropriate investment strategy. We seek to
 recommend investment strategies or products that will give you a diversified portfolio consistent with your
 investment objective. We do this by analyzing the various products, investment strategies, and money
 management firms to which we provide access. That analysis includes a review of the structure, cost, and
 investment performance history of each program.

 We may use one or more of the following methods of analysis and/or investment strategies when providing
 investment advice to you:

      • Fundamental Analysis – Involves analyzing individual companies and their industry groups, such as a
        company’s financial statements, details regarding the company’s product line, the experience and
        expertise of the company’s management, and the outlook for the company’s industry. The resulting data
        is used to measure the true value of the company’s stock compared to the current market value. The
        primary risk of fundamental analysis is that information obtained may be incorrect and the analysis may
        not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities
        prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable
        performance.

      • Technical Analysis – Technical analysis is a technique that relies on the assumption that current market
        data (such as charts of price, volume, and open interest) can help predict future market trends, at least
        in the short term. It assumes that market psychology influences trading and can predict when stocks will
        rise or fall. Technical trading models are mathematically driven based upon historical data and trends of
        domestic and foreign market trading activity, including various industry and sector trading statistics
        within such markets. Technical trading models, through mathematical algorithms, attempt to identify
        when markets are likely to increase or decrease and identify appropriate entry and exit points. The
        primary risk of technical trading models is that historical trends and past performance cannot predict
        future trends, and there is no assurance that the mathematical algorithms employed are designed
        properly, updated with new data, and can accurately predict future market, industry, and sector
        performance.

      • Charting – Charting is the set of techniques used in technical analysis in which charts are used to plot
        price movements, volume, settlement prices, open interest, and other indicators, in order to anticipate
        future price movements. Users of these techniques, called chartists, believe that past trends in these
        indicators can be used to extrapolate future trends.

      • Cyclical Analysis – Cyclical analysis is similar to technical analysis in that it involves the analysis of market
        conditions at a macro (entire market/economy) or micro (company specific) level, rather than the overall
        fundamental analysis of the health of the particular company. The primary risks with cyclical analysis are
        similar to those of technical analysis.

 We may use one or more of the following investment strategies when advising you on investments:

Liberty One Investment Management, LLC
Form ADV Part 2A

      • Long Term Purchases – Securities purchased with the expectation that the value of those securities will
        grow over a relatively long period of time, generally greater than one year. Using a long-term purchase
        strategy generally assumes the financial markets will go up in the long-term which may not be the case.
        There is also the risk that the segment of the market that you are invested in or perhaps just your
        particular investment will go down over time even if the overall financial markets advance. Purchasing
        investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized
        in the short-term in other investments.

      • Short Term Purchases – Securities purchased with the expectation that they will be sold within a
        relatively short period of time, generally less than one year, to take advantage of the securities' short-
        term price fluctuations. Using a short-term purchase strategy generally assumes that we can predict how
        financial markets will perform in the short-term which may be very difficult and will incur a
        disproportionately higher amount of transaction costs compared to long-term trading. There are many
        factors that can affect financial market performance in the short-term (such as short-term interest rate
        changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer periods of
        times.
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