Popular Securities LLC

Fees and Compensation - Item 5

      Advisory Fees
      Popular Securities’ annual advisory fee (also known as the “Total Client Fee”) for the services it
      provides to clients in the FMAX Program, or the Fixed Income Program has a cap of 2.50% or
      1.10% respectively, of your total assets invested in the FMAX Program or the Fixed Income
      Program, as applicable. The total client fee is negotiated on a case-by-case basis and it can be
      determined by considering several factors (i.e. anticipated future earning capacity, anticipated
      future additional assets, dollar amount of assets to be managed, related accounts, account
      composition, negotiations with client, etc.). The total client fee will be disclosed in your
      investment management agreement or statement of investment selection. You should note that
      an advisory fee greater than 2.00% of the total assets under management is higher than industry
      norms.

      Advisory fees are charged on a calendar quarter basis in advance, based on the value (market
      value or fair market value in the absence of market value) of the account at the end of the
      quarter and prorated to the end of the quarter upon inception of the account. Fees will be
      debited from the account in accordance with your initial authorization.

      The Total Client Fee is a composite fee calculated either from a fee schedule based on the asset
      levels (or “tiers”) invested, also known as “Tier Rate Fees”, or from a single fee, also known as an
      “All Assets Fee Rate”, applicable to all assets invested in the account regardless of the total asset
      levels or tiers. In both cases, the Total Client Fee Rate is composed of the “Program Fees”, as
      described below, the “Advisor Fees” and the “Firm Fees”, depending on the type of strategy
      selected. The Advisor Fees are fees paid directly to the Investment Advisor for the services
      rendered.

      Generally, if the total client fee is calculated based on “tier rates”, the overall fee rate will
      decrease, as the asset value in the account increases. With an “All Assets Fee Rate” structure,
      although the total client fee rate remains fixed, the program fees and the advisor fees could
      fluctuate over time. In these cases, if the program fee rates decrease, the advisor fee rate could
      increase.

      You will receive a separate disclosure document (Form ADV Part 2 Brochure) prepared by FIWA
      or the applicable investment adviser describing the specific fees charged within the FMAX
      Program or the Fixed Income Program, as applicable, the minimum account requirements, billing
      arrangements and service termination provisions. You are encouraged to review this disclosure
      document, as well as the investment management agreement, regarding the particular
      characteristics of the fees charged within the applicable program. Fees payable for your
      participation under the FMAX Program or the Fixed Income Program, as applicable (the
      “Program Fees”), are separate and in addition to the Advisor Fees paid to Popular Securities.

Popular Securities, LLC
Form ADV Part 2A

      Program Fees
      FMAX and/or the Fixed Income Manager will charge you a Program Fee that is established and
      payable in accordance with the applicable investment adviser’s disclosure documents and any
      written agreements you are required to execute in connection with the FMAX Program and/or
      the Fixed Income Program. The Program Fees are based on a percentage of assets under
      management and are billed quarterly in advance by the applicable investment adviser based on
      the market value of the assets on the last day of the preceding quarter. Fees will be assessed pro
      rata in the event the services agreement is executed at any time other than the first day of a
      calendar quarter. The Program Fee for each quarter will equal (on an annualized basis) the
      percentage set forth in the Fee Schedule, of the fair market value of the assets under
      management in the applicable category (including interest paid or accrued) as calculated on the
      last business day of the pervious calendar quarter. The Investment Adviser will determine the
      fair market value of the assets under management for purposes of calculating the Program Fee.
      If the investment management agreement is terminated prior to the end of a quarter, a pro rata
      portion of the Program Fee will be reimbursed to you.

      Popular Securities and applicable investment advisers are authorized, pursuant to your
      investment advisory agreement with such advisers, to instruct NFS to deduct from your account
      the Program Fees payable for services rendered under the aforesaid agreements. NFS shall
      retain the custodial fee due to NFS in connection with the applicable program and shall disburse
      the remainder of the Program Fee to Popular Securities and/or the applicable investment advisor
      in accordance with your investment management agreement or statement of investment
      selection. FMAX or the Fixed Income Manager, as agent for you, shall retain or distribute to Sub-
      Managers and any third-party service providers any amounts due such parties in connection with
      the FMAX Program or the Fixed Income Program, as applicable. NFS will not determine whether
      fees are properly calculated. It is your responsibility to verify the accuracy of such fee
      calculation.

      Program Fees are composed of Custody Fees, Platform Fees and Manager Fees.

      The agreed upon fees and terms will be stated in your investment advisory agreement with the
      applicable investment adviser(s).

      There is a minimum annual Program Fee charged per account for participation in the FMAX
      Program or the Fixed Income Program. The Program Fee does not cover certain charges
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Types of Clients - Item 7

      We offer advisory services to a wide array of clients, including, individuals, high net worth
      individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, non‐profit
      organizations, governmental organizations, corporations and certain private equity funds.

      Popular Securities’ minimum initial account size requirement is $50,000 for certain products.
      Many products may have a higher minimum requirement. However, the minimum requirement
      may be waived if you appear to have significant potential for increasing your assets under
      management. Minimum account requirements may also be reduced or waived for eligible
      employees of Popular Securities and its affiliates in accordance with firm policy. We may also
      combine account values for you and your minor children, joint accounts with your spouse, and
      other types of related accounts to meet the stated minimum. While the minimum account size
      requirement may be negotiable, a lower than required minimum size may result in higher fees.
      Your advisory relationship may be terminated if your account falls below a minimum size which
      is too small to manage effectively.

       You will receive a separate disclosure document (Form ADV Part 2 Brochure or equivalent
       brochure) prepared by the Fixed Income Manager, FIWA and/or Sub-managers, as applicable,
       describing account minimums and any other requirements for opening an account within the
       FMAX Program or the Fixed income Program. You are encouraged to review all disclosure
       documents to learn more about account requirements.

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

      We may use a variety of investment strategies and analytical methods in formulating its
      investment advice. The strategies and analysis methods used will depend on the specific
      situation being evaluated, but in general will be based on the client’s goals, risk tolerance, needs
      and current holdings, amongst others. These will be used to determine an asset allocation and
      suitable investment vehicles as well as to monitor and suggest on‐going monitoring and
      recommendations. Analysis may include but is not necessarily limited to several quantitative
      techniques and qualitative evaluations.

Popular Securities, LLC
Form ADV Part 2A

      We may also use one or more third‐party services for manager/fund research and due diligence;
      and Popular Securities may also conduct its own research and due diligence for certain
      strategies, managers, and funds.

      Third-Party Investment Analysis
      Investment research and due diligence of investment vehicles, available on the FMAX Program,
      will be conducted by FIWA. FIWA will rate each type of investment in one of four ratings:
      “Available”, “Meets-Quantitative”, “Meets-Qualitative”, and “Preferred”. These ratings may
      change without notice but will be communicated to Popular Securities. Popular Securities will
      determine what investments are appropriate and in the best interest of specific clients.

      FIWA’s Research Team performs the investment due diligence for the FMAX Program. Different
      solutions will demand unique due diligence process, all FIWA evaluations follow a systematic
      process.

      For actively and passively managed Funds available on the Platform, a quantitative rating process
      is performed to determine if the Fund meets the criteria to be awarded a Meets-Quantitative
      rating. The quantitative rating process is performed at least quarterly. A concurrent qualitative
      due diligence process is conducted on a select group of investment vehicles to provide deeper
      coverage and to determine if a Meets-Qualitative or Preferred rating should be applied. The
      qualitative rating process is performed at least annually. When combined, these processes result
      in the list of Meets and Preferred investment vehicles. Both quantitative and qualitative
      processes are executed simultaneously and continuously for ongoing evaluation of the
      characteristics of the investment options on the Platform. Both the quantitative and qualitative
      processes follow a common structure of assessing four major pillars of analysis: performance,
      cost, style alignment, and people and process consistency. For asset allocated strategies, such as
      investment manager’s model portfolios within the FSP Program, additional information about
      the portfolio construction process is considered given the importance of multi asset allocation
      techniques.

      Preferred
      Preferred investment vehicles have FIWA’s highest conviction and are comprised of a subset of
      Meets-Qualitative investment vehicles. For Preferred investment vehicles, the FIWA Research
      Team completes the due diligence process mentioned above for Meets-Qualitative. In addition,
      the FIWA Research Team conducts a quarterly touchpoint with one or more members of the
      product’s investment team. The FIWA Research Team seeks to understand the drivers of
      differentiation that allow these investment options to stand out across the four pillars of
      research. Investment vehicles sponsored by Investment Managers that Fidelity has deemed not
      to be in good standing on Fidelity FundsNetwork, Fidelity’s mutual fund platform, due to
      insufficient shareholder servicing compensation are not eligible for consideration for a
      “Preferred” research rating but are eligible to receive a “Meets-Quantitative” or “Meets-
      Qualitative” research rating.

      Additional Information
      The investment advice provided along with the strategies we suggest will vary depending on
      each client’s specific financial situation and goals. Investing in securities involves risk of loss that
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