Pruneyard Financial Group Inc

Item 5 - Fees and Compensation
This section details the fees and compensation we receive for our services. Lower fees for comparable
services may be available from other sources.

Fee Schedule

Portfolio Management Fees

The Firm’s advisory services are offered primarily through a wrap fee program. Clients participating in
the wrap fee program pay a single asset-based fee (the “wrap fee”) for investment advisory services. The
wrap fee is calculated as a percentage of assets under management not to exceed 1.25%.

Clients may either agree to a single annual billing rate based on a percentage of AUM, or a tiered fee
based on total household AUM. Our tiered fee rates are as follows

      Rate Tier                                                    Annual Fee      Monthly Rate
                          Total Household Assets Under
                                 Management*

          1                    $0.00 - $499,999.99                    1.25%           0.10%

          2                  $500,000 - $999,999.99                   1.00%           0.08%

          3                $1,000,000 - $2,499,999.99                 0.90%           0.08%

          4                $2,500,000 - $4,999,999.99                 0.80%           0.07%

          5                        $5,000,000 +                       0.50%           0.04%

Our Tiered Pricing is graduated. For example, for a sample $1,000,000 account:
    • For that portion of the client’s account(s) up to $499,999.99, PFG will charge an annual fee of
        1.25%, resulting in an annual fee of $6,250 on the first $500,000; plus
    • For that portion of the client’s account(s) exceeding $500,000 but not exceeding $1,000,000, the
        Adviser will charge an annual fee of 1.00%, resulting in an annual fee of $5,000 on the portion
        between $500,000 and $1,000,000.
    • This would result in a total annual fee of $11,250 on the sample $1,000,000 account.

Our advisory fees are negotiated and agreed upon prior to our onboarding a client. Client facts,
circumstances, and needs are considered in determining the fee schedule, including the complexity of the
client, assets to be placed under advisement, related accounts, and account composition and reports,
among other factors. The specific fee schedule is identified in each contract between our firm and the
client. The client should be aware that lower fees for comparable services may be available from other
sources.

Clients should be aware that the wrap fee may be higher than the aggregate cost of paying for advisory
services and transaction costs separately, depending on the level of trading activity in the account.
Additional details regarding the Program, including the services provided and the fees and expenses
covered by the wrap fee, are described in the Firm’s Form ADV Part 2A Appendix 1 (Wrap Fee Program
Brochure), which clients are encouraged to review carefully.

Clients may terminate our services via written notice to the firm. You will incur a pro rata charge for
services rendered prior to the termination of the agreement, which means you will incur advisory fees
only in proportion to the number of days in the month during which you are a client.

Payment of Fees

Program fees are charged monthly in arrears. If management begins after the start of a month, Program
fees will be prorated accordingly. When authorized by the client, fees will be debited from the account in
accordance with the terms set forth in the Investment Management Services Agreement. See Item 15 for
more information on direct fee deduction.

Other types of fees or expenses
The wrap fee is designed to cover most costs associated with the Program, including our investment
management (e.g., investment advice, portfolio management, and financial planning), administrative
expenses (e.g., custodial fees), and brokerage costs (to the extent trades are conducted through Schwab or
Fidelity). The Program fees do not include expenses of mutual funds and electronically traded funds such
as fund management fees charged to each fund's investors.

Prepayment of Fees

PFG does not collect fees in advance.

Outside Compensation For the Sale of Securities to Clients

Neither PFG nor its supervised persons accept any compensation for the sale of investment products,
including asset-based sales charges or service fees from the sale of mutual funds.

Types of Clients

We provide advisory and portfolio management services to the following types of clients:
   • Individuals (other than high net worth individuals)
   • High net worth individuals
   • Corporations or small business

Item 6 - Portfolio Manager Selection and Evaluation
Portfolio Manager Selection
As previously disclosed, all participating clients' assets are managed by advisory personnel of our firm.
These individuals must possess, in minimum, a college degree and/or appropriate business experience
and all required licenses. Please refer to Item 4 for detailed disclosures regarding the portfolio
management services we provide to program clients.

Portfolio Performance Reporting
Pruneyard Financial Group, Inc. publishes and distributes a quarterly report for each client that includes
information relevant to their portfolio, such as a portfolio’s asset allocation, investment performance,
unrealized gain/loss, and billing summary. Performance is presented as the time weighted rate of return
(TWR) for an account, net of fees. The S&P 500 Composite Index and Bloomberg Aggregate Bond Index
are displayed alongside the account performance values for discussion purposes.

Affiliated Portfolio Managers
As previously disclosed, all client assets in this program are managed by our portfolio managers. Please
refer to Item 4 for a detailed description of PFG Money Management Program's services and fees.

Performance-Based Fees
PFG does not charge performance-based fees.

Methods of Analysis and associated risks
We use the following methods of analysis in formulating our investment strategies:

Charting. In this type of technical analysis, we review charts of market and security activity to better
identify when the market is moving up or down and to predict how long the trend may last and when that
trend might reverse.

Technical Analysis. We analyze past market movements and apply that analysis to the present to better
recognize recurring patterns of investor behavior and potentially predict future price movement. Technical
analysis does not consider the underlying financial condition of a company. This presents a risk that a
poorly managed or financially unsound company may underperform regardless of market movement.

        Risks. The risk of market timing based on technical analysis is that charts might not accurately
        predict future price movements. Current prices of securities may reflect all information known
        about the security and day to day changes in market prices of securities may follow random
        patterns and may not be predictable with any reliable degree of accuracy.

Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic and
financial factors (including the overall economy, industry conditions, and the financial condition and
management of the company itself) to determine if the company is underpriced (indicating it may be a
good time to buy) or overpriced (indicating it may be time to sell).

        Risks. Fundamental analysis does not attempt to anticipate market movements. This presents a
        potential risk, as the price of a security can move up or down along with the overall market
        regardless of the economic and financial factors considered in evaluating the stock.

Quantitative Analysis. We use mathematical models to better obtain more accurate measurements of a
company's quantifiable data, such as the value of share price or earnings per share and predict changes to
that data.

          Risks. A risk in using quantitative analysis is that the models used may be based on assumptions
        that prove to be incorrect.

Qualitative Analysis. We subjectively evaluate non-quantifiable factors such as quality of management,
labor relations, and strength of research and development factors not readily subject to measurement and
predict changes to share price based on that data.

        Risks. A risk is using qualitative analysis is that our subjective judgment may prove incorrect.

Mutual Fund and/or ETF Analysis. We look at the experience and track record of the manager of the
mutual fund or ETF to better determine if that manager has demonstrated an ability to invest over a period
and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF to
better determine if there is a significant overlap in the underlying investments held in other fund(s) in the
client's portfolio. We also monitor the funds or ETFs to better determine if they are continuing to follow
their stated investment strategy.

        Risks. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past
        performance does not guarantee future results. A manager who has been successful may not be
        able to replicate that success in the future. In addition, as we do not control the underlying
        investments in a fund or ETF, managers of different funds held by the client may purchase the
        same security, increasing the risk to the client if that security were to fall in value. There is also a
        risk that a manager may deviate from the stated investment mandate or strategy of the fund or
        ETF, which could make the holding(s) less suitable for the client's portfolio.

Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the companies
whose securities we purchase and sell, the rating agencies that review these securities, and other publicly
available sources of information about these securities, are providing accurate and unbiased data. While we
are alert to indications that data may be incorrect, there is always a risk that our analysis may be
compromised by inaccurate or misleading information.

Investment Strategies

We use the following strategies in managing client accounts, provided that such strategies are appropriate
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