New Frontier Advisors LLC

ITEM 5: FEES AND COMPENSATION
                                Fees under the Sponsor Firm Model

Our annual fees for investment advisory services via Sponsor Firms, using model portfolios, are
based upon a percentage of assets under management and generally range from 0.10% to 0.35%
per annum depending on the Sponsor Firm, and to a lesser extent the model chosen and account
size.

New Frontier provides advisory services to unaffiliated Sponsor Firms that offer an "open-
architecture" investment platform ("Program") to Financial Advisors. New Frontier provides model
portfolios that are designed to satisfy the Sponsor Firm’s investment objectives, which are then
offered to Financial Advisors through the Program. Under such an agreement, the Financial
Advisor or Sponsor Firm may recommend that New Frontier Model Portfolios be used for a Financial
Advisor’s underlying client account. When a New Frontier Model Portfolio is utilized, the Sponsor
Firm will pay New Frontier's model portfolio management fee on behalf of the underlying client or
authorize payment of fees directly from the underlying client account.

New Frontier’s fees are invoiced on a Sponsor-by-Sponsor basis. Some Sponsor Firms are invoiced in
arrears at the end of each calendar quarter based upon the value (market value or fair market
value in the absence of market value, plus any credit balance or minus any debit balance), of the
Sponsor Firm’s account at the end of the previous quarter or the average balance of the Sponsor
Firm’s account during the quarter. Other Sponsor Firms are invoiced in advance at the beginning
of each calendar quarter based upon the value of the Sponsor Firm’s account at the end of the
previous quarter. Underlying clients should consult their Financial Advisor or Sponsor Firm for
information about any fees applicable to their accounts.

                                    Fees Under the Direct Model

Fees in the Direct Model are higher than in the Sponsor Firm Model due to the greater trading and
administrative duties required of New Frontier. The fees are based upon a percentage of assets
under management and will not exceed 0.45% per annum depending account size. The fees are
typically paid quarterly in advance based on the account value on the last business day of the
preceding calendar quarter. The fees discussed here are the portfolio management fees charged
by New Frontier only. Direct Clients will be charged additional fees by their Financial Advisor and
custodian.
                                    Fees for Friends and Family

Fees for Friends and Family are subject to negotiation at New Frontier’s discretion. The fees are
based upon a percentage of assets under management and will not exceed 0.60% per annum.
The fees are typically paid quarterly in advance based on the account value on the last business
day of the preceding calendar quarter. The fees discussed here are the portfolio management
fees charged by New Frontier only and do not include financial planning services.

                                 Fees for Tax Management Service

For accounts in the Direct Model, New Frontier can be engaged to perform tax management in
connection with taxable assets beyond a tax-sensitive model portfolio. This service is on a
discretionary basis and subject to any reasonable parameters provided by the Advisor. Our
optional Tax Management Services incur an additional 0.10% annual fee, which creates a conflict
of interest because we have an incentive to recommend the service. Tax management may
increase trading, realize gains/losses, create tracking error versus the reference model, and could
be limited by wash sale rules or client-imposed constraints.

                                      Fees for Custom Portfolios

Custom Portfolios are available under the Direct Model. The fees are based upon a percentage
of assets under management and will not exceed 0.50% per annum depending on the
customization, tax services, and account size. The fees are typically paid quarterly in advance
based on the account value on the last business day of the preceding calendar quarter. The fees
discussed here are the portfolio management fees charged by New Frontier only. Direct Clients
will be charged additional fees by their Financial Advisor and custodian.

                                       Service Fees for Indices

The service fees for the development of indices can vary from client to client. If we charge a basis
point fee, it will be based on the assets under management for any investor whose ETF or mutual
fund tracks the index. This fee will be collected quarterly in arrears by New Frontier. If a flat fee is
negotiated, the fee will be collected quarterly in arrears.

DISCLOSURE: In the event New Frontier incorporates an ETF or mutual fund, which is tracking our
index, into our model portfolios, the assets under management invested by New Frontier will be
exempt from the service fee in order to avoid any possible conflict of interest.

Limited Negotiability of Advisory Fees: Although New Frontier has established the fee schedule(s)
shown above, we retain the discretion to negotiate alternative fees on a contract-by-contract
basis. The complexity of the Program, assets to be placed under management, account
minimums, anticipated future additional assets, related accounts, portfolio style, account
composition, reports, and other factors will be considered in determining the fee schedule. The
specific annual fee schedule will be identified in the contract between New Frontier and the
Sponsor Firm or Financial Advisor, as applicable.

Termination of the Advisory Relationship: A Sponsor Firm agreement may be canceled at specific
times as outlined in the agreement. Generally, this is upon renewal or at will with advance notice.
In the event that fees are paid in advance of services provided, upon termination of any account,
any prepaid, unearned fees will be promptly refunded. In calculating a Sponsor Firm’s
...

ITEM 7: TYPES OF CLIENTS
As discussed in Items 4 and 5 of this Brochure, New Frontier provides advisory services via model
portfolios which are available to Sponsor Firms (through their Platforms) or directly to third-party
Financial Advisors. New Frontier provides services to their underlying clients solely as a sub-advisor
to such clients’ Financial Advisors.

We generally impose a $50,000 account minimum for each underlying client for our investment
advisory services via the Sponsor Firm Model. However, this minimum is negotiable, and some
platforms have lower minimums available. This account size is generally negotiated based on the
Sponsor Firm’s business and the liquidity requirements of the product.

For the Direct Model, we impose a $100,000 account minimum per Direct Client account for our
investment advisory services, as New Frontier accepts additional operational responsibilities in
connection with Direct Model accounts. This minimum can be negotiated based on the advisor’s
business and the liquidity requirements of the product, but smaller sized accounts may not match
the performance of larger accounts.

For Custom Portfolios, we impose $1,000,000 account minimum per household for our custom
portfolio services. This minimum can be negotiated based on the advisor’s business and the
liquidity requirements of the product, but smaller sized accounts may not match the performance
of larger accounts.

For Friends and Family, we impose a household minimum of $1,000,000 for our investment advisory
services with tax management.

For Tax Overlay Services, we don’t recommend the services for accounts that are less than
$1,000,000. However, the minimum is negotiable.