Ricketts Financial LLC

Item 5. Fees and Compensation
      Ricketts Financial offers services on a fee basis based upon assets under management or advisement.
      Additionally, certain of the Firm’s Supervised Persons, in their individual capacities, offers securities
      brokerage services and/or insurance products under a separate commission-based arrangement.

      Investment and Wealth Management Fees

      Ricketts Financial offers investment management and wealth management services for an annual fee based
      on the amount of assets under the Firm’s management. This management fee varies between 25 and 125
      basis points (0.25% – 1.25%), depending upon the size and composition of a client’s portfolio, the type and
      amount of services rendered and the individual(s) providing the services.

      The annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets
      being managed or advised by Ricketts Financial on the last day of the previous quarter. If assets are
      deposited into or withdrawn from an account after the inception of a billing period, the fee payable with
      respect to such assets is not adjusted to reflect the interim change in portfolio value. The Firm includes
      cash in a client’s account in determining the valuation for billing purposes. The Firm may, in its sole
      discretion, not include cash in determining the fee, especially where a client has a high percentage of cash
      for reasons other than the Firm's investment management decision. For the initial period of an engagement,
      the fee is calculated on a pro rata basis. In the event the advisory agreement is terminated, the fee for the
      final billing period is prorated through the effective date of the termination and the outstanding or unearned
      portion of the fee is charged or refunded to the client, as appropriate.

      Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g.,
      held-away assets, accommodation accounts, alternative investments, etc.), Ricketts Financial can negotiate
      a fee rate that differs from the range set forth above. Clients are advised that a conflict of interest exists for
      the Firm to recommend that clients engage Ricketts Financial for additional services for compensation,
      including rolling over retirement accounts or moving other assets to the Firm’s management. Clients retain
      absolute discretion over all decisions regarding engaging the Firm and are under no obligation to act upon
      any of the recommendations.

      Retirement Plan Consulting Fees
      Ricketts Financial charges an asset based fee to provide clients with retirement plan consulting services.
      Each engagement is individually negotiated and tailored to accommodate the needs of the individual plan
      sponsor, as memorialized in the Agreement. These fees vary, based on the scope of the services to be
      rendered, and ranges similar to the management fees (0.25% – 1.25%), depending upon services provided
      and the amount of assets to be advised on.

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 Disclosure Brochure                                                              Ricketts Financial, LLC

      Fee Discretion

      Ricketts Financial may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria,
      such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to
      be managed, related accounts, account composition, pre-existing/legacy client relationship, account
      retention, pro bono activities, or competitive purposes.

      Additional Fees and Expenses

      In addition to the advisory fees paid to Ricketts Financial, clients also incur certain charges imposed by
      other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions
      (collectively “Financial Institutions”). These additional charges include securities brokerage commissions,
      transaction fees, custodial fees, fees charged by the Independent Managers, margin and other borrowing
      costs, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s
      prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot
      differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage
      accounts and securities transactions. The Firm’s brokerage practices are described at length in Item 12,
      below.

      Direct Fee Debit

      Clients provide Ricketts Financial and/or certain Independent Managers with the authority to directly debit
      their accounts for payment of the investment advisory fees. The Financial Institutions that act as the
      qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees,
      have agreed to send statements to clients not less than quarterly detailing all account transactions, including
      any amounts paid to Ricketts Financial.

      Use of Margin

      Ricketts Financial can recommend that certain clients utilize margin in the client’s investment portfolio or
      other borrowing. Ricketts Financial only recommends such borrowing for non-investment needs, such as
      bridge loans and other financing needs. Client’s may also choose (without the Firm’s advice) to use margin
      or other borrowing for investment purposes. The Firm’s fees are determined based upon the value of the
      assets being managed gross of any margin or borrowing.

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Item 7. Types of Clients
      Ricketts Financial offers services to individuals, trusts, estates, corporations and other business entities, and
      pension and profit sharing plans.