Riverfront Investment Group LLC

Item 5 – Fees and Compensation
RiverFront is compensated by receiving a mutually agreed upon fee that is a percentage of assets under
management in a client account. The more assets there are in your advisory account, the more you will pay in
fees, RiverFront therefore has an incentive to encourage you to increase the amount of assets in your account.
As described below, clients pay different fees based on differing fee schedules, product, or the size of the account,
RiverFront has an incentive to favor those accounts where it earns the highest fees.

RiverFront maintains investment, trade allocation, and account valuation policies and procedures to address such
conflicts of interest. Further, investment performance return dispersion is reviewed regularly by the Investment
Committee to reasonably ensure certain clients are not favored over other clients.

Model Portfolios
Advantage and ETF Advantage SMAs

In these portfolios, clients generally pay an asset-based fee to the Sponsor Firm; out of that fee, the Sponsor Firm
is responsible for paying an investment advisory fee to RiverFront as the manager of the SMA. RiverFront’s
advisory fees are charged quarterly or monthly in advance or in arrears, depending on the Sponsor Firm. Fees paid
in advance are based on the market value of the Sponsor Firm’s client’s assets under management at the end of
the prior calendar quarter. Fees paid in arrears are based on a client’s assets under management at the end of
the quarter.

These fees are typically deducted by the Sponsor Firm directly from a client’s account. In some cases, negotiation
of fees will result in different fees being charged for similar services and may be less than the stated fee schedule.
In the event that a client terminates the advisory relationship and fees have been paid in advance, RiverFront’s
investment advisory fee is prorated through the effective date of termination, and any remaining balance is
refunded to the client. Because RiverFront’s fee is asset-based, RiverFront’s advisory fee will increase if the
market value of the client’s account increases. RiverFront will not be compensated on the basis of a share of
capital gains or capital appreciation of client accounts. When RiverFront applies an asset-based fee to an account’s
assets, the fee is applied to all assets in the account, including but not limited to: cash, cash equivalents, and any
securities that the client has requested RiverFront to hold or manage differently to minimize capital gains. For
information on your specific billing schedule, please contact your Financial Advisor.

Advantage and ETF Advantage SMAs – Contractual Arrangements

Clients who select RiverFront to manage their assets within Advantage or ETF Advantage SMAs will typically do so
under either a “single contract” or “dual contract” arrangement.

Under a single contract arrangement, the client pays an asset-based fee to the Sponsor Firm; out of that fee, the
Sponsor Firm is responsible for paying an investment advisory fee (as described above) to RiverFront. In these
programs, the Sponsor Firm and RiverFront enter into a sub-advisory or other agreement under which RiverFront
agrees to manage the assets. As part of that agreement, RiverFront and the Sponsor Firm agree on the investment
advisory fees to be charged by RiverFront. RiverFront’s advisory fees are negotiable and will vary from program to
program, but typically do not exceed 0.50% per year on a client’s account assets under management, calculated on a
quarterly basis as described above. There are other non-asset-based fees that will be charged to the client as
discussed below and in Item 12 of this Brochure.

Under a dual contract arrangement, the client has one contract with the Sponsor Firm and another contract with
RiverFront. As such, the client pays RiverFront an investment advisory fee in addition to the asset-based fee
they pay to the Sponsor Firm for investment advice, custody, execution, and reporting. RiverFront’s advisory fee
is negotiable, but typically does not exceed 0.50% per year on a client’s account assets under management,
calculated on a quarterly basis as described above.

Specific information on the investment advisory fees payable to RiverFront under a wrap fee program will be
provided by the applicable Sponsor Firm. For information on the asset-based fees charged by the Sponsor Firm,
clients should consult with the Sponsor Firm or refer to the Sponsor Firm’s Wrap Fee Program Brochure (also
known as ADV Part 2A Appendix 1).

Advantage and ETF Advantage UMA/MDPs

RiverFront has agreements with certain Sponsor Firms to provide model portfolios to UMA clients for a negotiated
fee. Under these arrangements RiverFront will not have any direct agreement with the client. RiverFront’s advisory
fees are negotiable and will vary from program to program, but do not exceed 0.45% per year on the value of the
client assets in the wrap fee program. RiverFront’s fees are generally charged quarterly in advance or in arrears
and are based on the market value of a client’s assets under management at the end of the prior calendar quarter.
These fees are typically deducted by the Sponsor Firm directly from a client’s account per their agreement with
the Sponsor Firm. In the event that a client terminates the advisory relationship and fees have been paid in
advance, RiverFront’s investment advisory fee is prorated through the effective date of termination, and any
remaining balance is refunded to the client.

RiverFront has agreements with certain MDPs to provide model portfolios for a negotiated fee; these fees can differ
but do not exceed 0.43%.

For information on the specific billing schedule that would be applicable to an account, please contact your
Financial Advisor.

RiverShares SMAs and UMA/MDPs

RiverShares portfolio solutions are model portfolios that invest in actively managed ETFs that are affiliated with
...

Item 7 – Types of Clients
RiverFront provides investment advice to a wide range of clients including, but not limited to, individuals, trusts,
estates, pension and profit-sharing plans, charitable organizations, and corporations. RiverFront also serves as
sub-adviser to investment companies. The minimum account size depends on the services offered and can be
waived or negotiated at RiverFront’s discretion. Advantage SMA minimums vary by Sponsor Firm and are generally
$100,000 or $200,000; ETF Advantage and RiverShares SMAs generally require a $100,000 minimum. CPS
accounts will require higher investment minimums, typically in excess of $750,000 per account and are
negotiated on a case-by-case basis. RiverFront does not have the ability to impose minimums on UMA or MDP
accounts. For investment minimums of the RiverFront ETFs, please see the relevant Fund’s prospectus.