on Investment Management Co

Item 5 – Fees and Compensation

    •    Comprehensive Financial Planning and Modular Planning relationships are charged a fee based upon an
         agreed upon amount prior to engaging in the planning relationship. Specialized Financial Services
         relationships are based on an hourly or fixed amount which is stated prior to engaging in the relationship.

    •    Clients utilizing ONIMCO’s Investment Advisory Services are charged a fee based on a percentage of
         assets under management as described below.

Fees for Financial Planning Services
Comprehensive Financial Planning and Modular Planning

The specific fee may vary from client to client based upon the complexity of a particular client’s financial position
as well as the complexity of the client’s financial objectives. The fee shall not generally exceed $5,000.00 unless an
ONIMCO Home Office Review Principal has reviewed the specific circumstances and authorized its Investment
Adviser Representative to charge a higher fee. The fee will be disclosed in writing through the Client Advisory
Agreement prior to engaging in the plan. By signing the Client Advisory Agreement, you acknowledge the amount
of the fee and agree to compensate ONIMCO for the services described. The IAR receives compensation for the
financial plan after the plan is reviewed and approved by a Financial Plan Review Principal and then delivered by
the IAR. If you decide to terminate the Financial Planning agreement prior to the completion of the plan, payment
will be owed for the time spent developing the financial plan prior to such termination. The amount due in the event
of the termination will be a pro-rata amount based upon the degree of completion of the financial plan at the time the
notification of termination was received.

Specialized Financial Services

The fee for Specialized Financial Services provided on an hourly basis are disclosed in writing on the Client
Advisory Agreement and cannot exceed $350/hr. or $5000/year unless an ONIMCO Home Office Review Principal
has specifically authorized the IAR to charge a higher fee. The hourly rate and the estimated number of hours
needed to complete the requested service will be disclosed in writing through the Client Advisory Agreement prior
to engaging in the service. The number of hours needed to complete the plan will vary based upon the complexity of
the request. If you decide to terminate the Financial Planning agreement prior to the completion of the Specialized
Financial Services, payment will be owed for the time spent performing the services prior to such termination. The
amount due in the event of the termination will be the hourly rate previously agreed upon multiplied by the number
of hours the Investment Adviser Representative has spent on the services.

Specialized Financial Services provided on a fixed basis are based on a pre-negotiated fee for an agreed upon time
period. The fee cannot exceed $5000/year unless an ONIMCO Home Office Review Principal has specifically
authorized the IAR to charge a higher fee. The time period for the relationship cannot exceed one year unless it is
renewed. The fixed fee will vary based upon the complexity of the request. If you decide to terminate the Financial
Planning agreement prior to the completion of the Specialized Financial Services, payment will be owed for the pro-
rated amount of time spent in the relationship.

Checks for Financial Planning Services must be made payable to ONIMCO.

         ONIMCO ADV Part 2A: Version 3/27/2026

Fees for Investment Advisory Programs
Summary

Each program sponsor available through ONIMCO has its own unique fee schedule. Program sponsors typically
provide a tiered fee schedule where larger account sizes may receive a reduced fee. A separate disclosure document
containing the fee schedule of the program sponsor and professional money manager will be provided upon
recommendation of that service and will be furnished by the program sponsor. Prior to investing, you should read all
disclosure materials carefully and consult with your Investment Adviser Representative to ensure your full
understanding of the fees involved and services provided within each program.

Fees for Investment Advisory Programs are deducted directly from your account quarterly and are based upon the
market value of the assets within the account. Direct billing of fees is not available. Accounts on the Envestnet and
SEI platforms are billed monthly based upon the market value of the assets within the account. The fees deducted
from the account are used to compensate the program sponsor, professional money managers (if applicable), the
account custodian, ONIMCO, and the Investment Adviser Representative. The IAR’s portion of the fees for the
managed account programs are negotiable and may be adjusted at the discretion of the individual IAR. Investment
Adviser Representatives may charge between .30% - 1.50% annually. This may not be inclusive of all fees.
Additional advisory fees may be charged depending upon the Third-Party Adviser selected. Please refer to the ADV
Part 2 of the specific Third-Party Adviser for their specific fee schedule. The advisory fee typically will be deducted
from the account by the custodian and paid quarterly in arrears, quarterly in advance, monthly in arrears or monthly
in advance depending upon the advisory program. ONIMCO clients with similar account size might not pay the
same fee. Similar services may be available from other investment advisory firms for fees which are lower than,
equal to, or higher than ONIMCO’s fees. Depending upon the Third-Party Adviser, additional fees may apply for
items such as custody and recordkeeping, annual account maintenance, or closing an account.

In addition to advisory fees, clients are charged, if applicable, individual retirement (“IRA”) annual maintenance
...

Item 7 – Types of Clients
ONIMCO advisers provide services to individuals, families, trusts, estates, charitable organizations, businesses, and
other organizations throughout the United States.

Financial Planning Services – Account Minimums

ONIMCO generally does not impose a minimum dollar of amount of assets in order to provide financial planning
services but reserves the right to do so on a case-by-case basis.

Investment Advisory Services - Account Minimums

The minimum investment amount needed to open an investment management account ranges from $0 - $2,000,000
depending upon both the Third-Party Program and the specific product selected within the adviser’s program. Each
adviser and product will have its own set minimum investment amount. Please refer to the Third-Party Adviser’s
materials for the specific account minimum for each product offering and consult with your Investment Adviser
Representative for further assistance.

         ONIMCO ADV Part 2A: Version 3/27/2026

       Item 8 – Method of Analysis, Investment Strategies, and Risk of Loss
Financial Planning Services

As part of the financial planning process, an ONIMCO Investment Adviser Representative will work closely with
you to collect important background information about your unique situation to help identify needs and
opportunities which will serve as the basis for the IAR’s recommendations. Comprehensive Financial Plans are
produced using computer software programs approved for use by ONIMCO. Financial Plans will typically explore
“what if” type scenarios allowing the IAR to present recommendations in consideration of these events. The
recommendations will typically be general in nature, yet unique to your specific situation. For example, the
recommendation may identify a need such as additional life insurance coverage for you and your spouse but will not
recommend the purchase of a specific company’s life insurance product. The recommendations will typically
address the tools and general investment categories that you should consider when implementing the plan but will
not offer specific legal or tax advice.

As part of the effort to understand your unique situation, the IAR may ask to review financial documents or may
coordinate a review with other professionals such as attorneys, accountants, or consultants that you currently work
with. Your investment adviser will help you analyze areas such as: asset allocation and investment planning,
income protection needs, tax considerations, retirement planning, education planning, estate planning, and other
areas. The recommended strategies in your plan will be based on careful analysis of the information you provided
about your current financial situation, risk tolerance, and long-term financial goals.

It is important to understand that any investment involves certain risks. ONIMCO and the Investment Adviser
Representative do not make any representation or provide any warranty as to any investment return that may or may
not be realized as a consequence of following the Financial Plan or Specialized Financial Services developed on
your behalf. You should understand that it is possible to lose money by implementing the Financial Plan or
Specialized Financial Services. Any recommendations or advice offered by ONIMCO and the Investment Adviser
Representative is not legal advice or accounting advice. You should coordinate and discuss the impact of any
financial advice with an attorney and/or tax professional.

Investment Advisory Services

If engaged to provide investment advisory services, the Investment Adviser Representative will first evaluate your
current financial situation, needs, goals, objectives, and tolerance for risk. Upon reviewing these factors the IAR will
assist you in selecting a Third Party Adviser and/or construct a portfolio to help you achieve your goals. Each
individual client’s situation is unique, so product selection may vary based upon your individual needs. Investment
decisions are then made to, in the IAR’s best judgment, help you achieve your overall financial objectives while also
attempting to minimize risk exposure. Asset allocation is a key component of investment portfolio design, but does
not assure a gain and does not prevent or prevent against a loss in declining markets. Some investment professionals
believe that the appropriate allocation of assets across diverse investment categories (stock vs. bond, foreign vs.
domestic, large cap vs. small cap, high quality vs. high yield, etc.) is the primary determinant of portfolio returns and
critical in the long-term success of one’s financial objectives. Tactical management strategies may also be utilized
by advisers. Tactical asset allocation is an active management portfolio strategy that shifts the percentage of assets
held in various categories to take advantage of market pricing anomalies or strong market sectors. Tactical
management may also be utilized by advisors in an attempt to protect against sustained market declines. However,
these strategies cannot guarantee success or specific rates of return. Recommendations provided may be based upon
publicly available reports, individual analysis, research materials and computerized asset allocation models.

No guarantees can be offered that your goals and objectives will be achieved. Additionally, no promises or
assumptions can be made that the advisory services offered through ONIMCO will provide a better return than other
investment strategies. The strategies that are recommended generally do not involve significant or unusual risk

         ONIMCO ADV Part 2A: Version 3/27/2026

beyond that of the general domestic and/or international equity and/or bond markets. Investing in securities involves
a risk of loss that you, as a client, should be prepared to bear.