Marshall Sterling Wealth Advisors Inc

Item 5. Fees and Compensation

The Firm offers its services on a fee basis, which can include fixed fees and/or hourly fees as well as fees based upon assets
under management. Additionally, certain of the Firm’s Supervised Persons, in their individual capacities, offer securities
brokerage services and/or insurance products under a separate commission-based arrangement.

Investment Management and Wealth Management Fees
For clients participating in the Program, the Firm’s investment management and wealth management fees are described in
the Firm's wrap fee disclosure brochure. Marshall+Sterling's annual investment management fee, for those clients not in the
Firm's wrap fee program, is exclusive of and in addition to brokerage commissions, transaction fees and other related costs
and expenses which are incurred by the client. Marshall+Sterling does not, however, receive any portion of these

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commissions, fees and/or costs. The Firm's annual fee is prorated and charged quarterly, in advance, based upon the market
value of the assets being managed by the Firm on the last day of the previous quarter. The annual fee generally varies
between 0.50% and 1.80% depending upon the market value of the assets under management and the type of investment
services to be rendered. Fees can fall outside of this general range for extraordinary circumstances where the scope and
complexity of services warrant such a higher or lower fee. The Firm may charge a fee at the higher end of the range for the
momentum strategy described above.

Fees for LPL Advisory Programs
The account fee charged to the client for each LPL advisory program is negotiable, subject to the following maximum account
fees:

                                        LPL Program             Maximum Account Fee
                                            SWM                           2.5%
                                             MAS                          2.5%
                                            MWP                          2.83%
                                            GWP                          1.35%

    •   MAS program fee consists of a platform fee, manager fee and adviser fee.
    •   MWP account fee consists of an LPL program fee, a strategist fee (if applicable) and an advisor fee of up to 2.00%.
        Accounts remaining under the legacy fee structure may be charged one aggregate account fee, for which the
        maximum account fee is 2.83%. See the MWP program brochure for more information.

    •   GWP Managed Service clients are charged an account fee consisting of an LPL program fee of 0.35% and an
        advisor fee of up to 1.00%. In the future, a strategist fee may apply. However, LPL Research currently serves as
        the sole portfolio strategist and does not charge a fee for its services.

    •   GWP Educational Tool provides access to sample recommendations at no charge to users. However, if users decide
        to implement sample recommendations by executing trades, they will be charged fees, commissions and/or
        expenses by the applicable broker or adviser, as well as underlying investment fees and expenses. Account fees
        are payable quarterly in advance, except that the SMS fee is paid in arrears on the frequency agreed to between
        client and adviser.

    •   Excluding GWP, LPL serves as program sponsor, investment advisor and broker-dealer for the LPL advisory
        programs. In the Managed Service of GWP, LPL is appointed by each client as custodian of account assets and
        broker-dealer with respect to processing securities transactions for the accounts.

Marshall+Sterling and LPL share in the account fee and other fees associated with program accounts. Associated persons
of Marshall+Sterling can also be registered representatives of LPL. The account fee can be higher than the fees charged by
other investment advisers for similar services. However, clients using such direct robo services will forgo opportunities to
utilize LPL-constructed model portfolios or to work directly with a financial adviser. Clients should consider the level and
complexity of the advisory services to be provided when negotiating the account fee (or the adviser fee portion of the account
fee, as applicable) with Marshall+Sterling.

Mutual Fund 12b-1 Fees

Section 206 of the Investment Advisers Act of 1940 ("Advisers Act") imposes a fiduciary duty to act in a client's best interests
and specifically prohibits investment advisers, directly or indirectly, from engaging in any transaction, practice or course of
business which operates as a fraud or deceit upon any client or prospective client. However, the fiduciary duty to which
advisers are subject is not specifically defined in the Advisers Act or the Commission rules but reflects a Congressional
recognition "of the delicate fiduciary nature of an investment advisory relationship" as well as a Congressional intent to
eliminate, or at least expose all conflicts of interest which might incline an investment adviser, consciously or unconsciously,
to render advice which was not disinterested.

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All 12b-1 fees incurred by client accounts are retained by LPL Financial LLC (LPL) as the qualified custodian. The purpose
of 12b-1 fees, as approved by the SEC, are to cover marketing expenses and shareholder services such as the support
services provided by LPL to offer the hybrid platform as well as "other expenses" such as the legal, accounting and
administrative services also provided by LPL for a hybrid firm to leverage. The more beneficial share class depends on an
analysis of all fees including ticket charges and expected 12b-1 fees. Investing in a 12b-1 fee paying share class can be less
...

Item 7. Types of Clients
The Firm provides its services to individuals, pension and profit-sharing plans, trusts, estates, corporations and other
business entities. The Firm does not require a minimum account size or minimum fee for opening or maintaining an account
with the Firm. Certain LPL accounts require a minimum amount of investable assets to open and maintain an account:

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     ■   A minimum initial account value of $200,000 is suggested for SWM. In certain instances, Marshall+Sterling may
         permit a lower minimum account value.

     ■   MWP requires a minimum asset value for a program account to be managed. The minimums vary depending on
         the portfolio(s) selected and the account's allocation amongst portfolios. The lowest minimum for a portfolio is
         $25,000. In certain instances, a lower minimum for a portfolio is permitted.

     ■   A minimum account value of $5,000 is required to enroll in the GWP Managed Service.
     ■   The MAS (Manager Access Select) requires a minimum asset value for the program to be managed. The minimums
         vary based on money manager and strategy, starting at $50,000.