RSG Investments LLC

Item 5 – Fees and Compensation

 In addition to the information provided in Item 4 – Advisory Business, this section provides additional details
 regarding our firm’s services along with descriptions of each service’s fees and compensation
 arrangements. It should be noted that lower fees for comparable service can be available from other
 sources. The exact fees and other terms will be outlined in the agreement between you and RSG
 Investments.

Fees for Asset Management Services through Third Party Advisors

The total annual Advisory Fee due to us for Asset Management Services (“Advisory Fee”) is negotiable at
the sole discretion of our firm and will be outlined in the Investment Advisory Agreement signed by the client
and our firm. The maximum annual Advisory Fee charged for these services will be up to 2% of the total
assets under management, and will include all fees payable to sub-advisers or third party investment
advisers (“TPAs”), unless otherwise agreed by you in a separate written agreement.

Advisory Fees are typically billed monthly in arrears based on each account's average daily balance during
the prior calendar month, depending on the sub-adviser recommended. The first monthly fee shall be
prorated based on the portion of such month remaining. Advisory Fees are negotiable and will be deducted
from client account(s) by either us or a sub-adviser. In rare cases, our firm will agree to direct bill clients.

The portion of the Advisory Fee payable to the sub-adviser or TPA is established and payable in accordance
with the brochure provided by each TPA to whom you are recommended. These fees may or may not be
negotiable. Because we pay the TPA’s advisory fee, our net compensation differs depending upon the
individual agreement we have with each TPA. Furthermore, different models made available through TPAs
also charge different fees; accordingly, our net compensation also differs depending upon the model
selected. Nevertheless, because the costs attributable to supporting the use of each TPA and model varies,
you should not assume that the use of any TPA or model that results in a higher net compensation to us is
necessarily more profitable to us than using a TPA or model that results in a lower net compensation to us.
Whenever we recommend a TPA or model that would result in a higher profit to us than a different TPA or
model, a conflict of interest arises where our firm or our Associated Persons may have an incentive to
recommend one TPA or model with whom we have more favorable compensation arrangements over other
advisory programs offered by TPAs with whom we have less favorable or no compensation arrangements.
We address this conflict of interest by ensuring our recommendations of TPAs and models are in our client’s
best interest.

Model Portfolio Solutions and Direct Asset Management Services Fees

Fees charged for our model portfolio solutions and direct asset management services are charged based
on a percentage of assets under management, billed in arrears (at the end of the billing period) on a monthly
calendar basis and calculated based on the average daily balance of the account(s) for the current billing
period. Fees are prorated based on the number of days service is provided during the initial billing period if
your account opened at any time other than the beginning of the billing period. Under the average daily
balance method, each day’s balance for the month is summed then divided by the number of days in the
month, to compute the average daily balance. The average daily balance is then multiplied by the monthly
portion of the annual fee to determine the monthly fee due.

The standard fee for our model portfolio solutions is 1.45%. The standard fee for our direct asset
management services is 0.90%. RSG Investments reserves the right to negotiate our fees on a client-by-
client basis, dependent upon the type of client, the complexity of the client's situation, the composition of the
client's account (i.e., equities versus mutual funds), the potential for additional account deposits, the
relationship of the client with the investment adviser representative, and the total amount of assets under
management for the client. The annual fee charged by RSG Investments will be specified in the client’s
written agreement. RSG Investments’ annual investment advisory fee may be higher than that charged by
other investment advisers offering similar services/programs.

Investment advisory fees will be deducted from your account and paid directly to our firm by the qualified
custodian(s) of your account. You must authorize the qualified custodian(s) of your account to deduct fees
from your account and pay such fees directly to RSG Investments. If an account is closed or terminates

during the month, a pro-rated fee will be charged. The rate will be determined by how many days the
account was serviced before it was closed or terminated. You should review your account statements
received from the qualified custodian(s) and verify that appropriate investment advisory fees are being
deducted. The qualified custodian(s) will not verify the accuracy of the investment advisory fees deducted.
At RSG Investments’ discretion, we may agree to bill you for fees incurred instead of deducting the fees
from your account.

In addition to the fees described above, you may incur certain charges imposed by third parties other than
RSG Investments in connection with investments made through your account including, but not limited to,
mutual fund sales loads, periodic mutual fund fees (e.g., 12b-1 trails) and surrender charges, IRA and
qualified retirement plan fees, and charges imposed by the qualified custodian(s) of your account. Advisory
fees charged by RSG Investments are separate and distinct from the fees and expenses charged by
investment company securities that may be recommended to you. A description of these fees and expenses
...

Item 7 – Types of Clients

RSG Investments generally provides investment advice to the following types of clients:

    •   Individuals
    •   High net worth individuals
    •   Trusts, estates, or charitable organizations
    •   Retirement and profit-sharing plans
    •   Corporations and other business entities

You are required to execute a written agreement with RSG Investments specifying the advisory services to
establish a client arrangement with RSG Investments.

Minimum Investment Amounts Required

RSG Investments requires a minimum balance per account of $10,000. Exceptions may be granted to this
minimum if approved by both your investment adviser representative and RSG Investments for a client’s
immediate family members or in anticipation of additional deposits.