Newfront Retirement Services Inc

Fees and Compensation
Form ADV Part 2A, Item 5

Fees for Services

Fees charged for services rendered are negotiated with the client and are based on a percentage of
plan assets under management, a fixed dollar amount, or a combination of both, depending upon the
type of service rendered. Fees are disclosed and agreed upon by all parties in the client service
agreement. Fixed dollar fees will not exceed $300,000 per year and asset-based fees will not exceed
2% annually, of assets under management. Clients who engage Newfront for multiple services are
charged a bundled fee. In some cases, fees may be waived at the sole discretion of Newfront.

Plan advisory services begin with the effective date of the agreement. The effective date of the
agreement becomes the date that our fees will be paid for each month or quarter going forward.
Our ongoing investment advisory fee is billed in arrears on the last business day of the rolling month or
quarter.

Invoices are sent out each quarter or month to either the plan client or to the custodian of the plan. For
clients where our fee is billed to the custodian, the fee is deducted directly from the plan account or
plan participant accounts. Written authorization permitting us to be paid directly from the custodial
account is outlined in the client service agreement. Fees for services that are invoiced directly to the
client are due and payable within 30 days of receipt of the invoice.

The firm may charge clients a plan onboarding fee not to exceed $50,000. The plan onboarding fee is

a one-time fee negotiated in advance with the client and detailed in the client service agreement. The
fee is dependent on a variety of factors, including time, location, number of plan participants, nature of
the services and complexity of the plan.

Consulting Services

Additional consulting services provided to clients will be billed at either an hourly rate not to exceed
$500 per hour, or as a flat fee. The specific fee to which a client is subject will be specified in a
separate service agreement signed by the client, and the fee will be directly billed to the client upon
completion of the services or upon presentation of an invoice.

Additional Fees and Expenses

Advisory fees payable to us do not include all the fees you will pay when administrating your
organization's retirement plan. We do not receive, directly or indirectly, any of these fees charged to
the client. The following list of fees or expenses are what you may pay directly to third parties:

    • Transaction fees;
    • Advisory fees and administrative fees charged by Mutual Funds (MF), Exchange Traded Funds
      (ETFs);
    • Advisory fees charged by sub-advisers (if any are used for your account);
    • Custodial Fees;
    • Wire transfer and electronic fund processing fees;

Please refer to "Other Financial Industry and Affiliations" under Item 10 below for a discussion of
Newfront compensation arrangements.

             Performance-Based Fees and Side by Side Management
Form ADV Part 2A, Item 6

We do not charge advisory fees on a share of the capital appreciation of the funds or securities in a
client account (performance-based fees). Our advisory fee compensation is charged only as disclosed
above in Fees and Compensation.

Types of Clients
Form ADV Part 2A, Item 7

We provide investment advice on pension, profit sharing plans, and non-qualified deferred
compensation plans to institutional clients. We do not have a minimum account size for providing our
services to clients and we do not currently offer advice to retail clients.

          Methods of Analysis, Investment Strategies and Risk of Loss
Form ADV Part 2A, Item 8

Newfront may assist you in the development of an investment policy statement and provide you with
information and recommendations about specific investment managers for each asset class defined in
your investment policy. Once the Investment Policy Statement is finalized, the search and selection
process for the investments is made utilizing only retirement specific share classes, load waived,
and/or no-load mutual funds. Newfront does not include, nor is authorized to make, recommendations

for the inclusion or purchase of individual stocks and bonds.

The principal sources of information for Newfront's recommendations come from publicly available
databases of mutual fund information. Occasionally, the use of proprietary charts and graphs prepared
by an independent investment advisor may be used.

Investment fund options will be selected following a systematic search for those with demonstrated
quality in the designated asset classes. Consideration will be given to an investment fund option
provider's range of available products as well as capabilities/availability in the retirement plan
marketplace.

Evaluation of Investment Fund Options

The following criteria will be used to evaluate investment fund option performance:

Performance Objectives for Investment Funds That Are Actively Managed

    1. The investment fund options will be expected to consistently achieve a total rate of return,
       which is equal to or above the median return in a universe of peers with comparable investment
       styles or portfolio objectives. Mutual fund investment options will be measured against the
       appropriate peer groups.
    2. Actively managed fund options may also be expected to achieve an annualized total rate of
       return over a three-to-five year period, which exceeds an appropriate market index rate of
       return net of costs and fees. The appropriate market index benchmark for each investment fund
       option will be determined based on the objectives and strategy of the fund. Total return is
       defined as dividend or interest income plus fair market value of realized and unrealized capital
       appreciation or depreciation at fair market value.

Selection Criteria

In selecting or replacing mutual funds, the following criteria will be considered:

    •   Change in portfolio manager(s)
    •   Organizational changes
    •   Inconsistency in strategy, style, and investment approach
    •   Publicly reported material regulatory or compliance issues
    •   Three-year return below index
    •   Five-year return below index
    •   Three-year return below peer median
    •   Five-year return below peer median
    •   Expenses compared to the fund category and peer group.

Investment strategies used to implement any investment advice given to clients focus on long-term
purchases. Investing in securities involves risk of loss that clients should be prepared to bear. The
performance of most of these investments depends on what happens in the stock market. The
market's behavior is unpredictable, particularly in the short term. The investments recommended are
mutual funds, variable annuities, and collective investment trusts; they are not a bank deposit and are
not guaranteed or insured by the Federal Deposit Insurance Corporation or any other government
agency. The value of client investments may fall, sometimes sharply, and they could lose money. The
following factors can significantly affect the performance of our clients' investments: Stock Market

Volatility - Stock markets are volatile and can decline significantly in response to adverse issuer,
political, regulatory, market, or economic developments. Diversification - Investing a higher percentage
of assets in any one fund or asset class could increase the risk of loss. Recent Market Conditions -
Recent events in the financial sector have resulted, and may continue to result, in an unusually high
degree of volatility in the financial markets, both domestic and foreign, and in the net asset values of
many mutual funds. Because the situation is unprecedented and widespread, it may be unusually
difficult to identify both risks and opportunities using past models of the interplay of market forces, or to
predict the duration of these market events.