Savvy Financial Inc

Fees and Compensation
Compensation for Advisory Services
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Employer Related Accounts
Fee arrangements between SavvyFi and other firms (the “employer”) are negotiated by separate
contract. Any variation of the fee arrangement is due to specific requests and/or requirements of
individual employers. Typically, when clients sign up for SavvyFi’s Services through their employer,
SavvyFi is compensated for its Services by the Client’s employer based on the contract in place. Fees
are taken at the first of each month once the account has been active for thirty (30) days or more. Any
account opened outside of the employer will be associated with a separate Client Agreement.

SavvyFi’s Fee is separate from the annualized fees and expenses of the Custodian’s 529 Plan, which
may include underlying administrative, investment management, program management, and fund
fees.

529 Plan’s fees are deducted directly from the Client’s 529 Account and, therefore, indirectly affect the
Client’s portfolio performance. Clients should review the Custodian's Record Keeper’s 529 Program
Description prior to entering into this Agreement.

Individual Accounts
SavvyFi is compensated for its Services in connection with the Client’s 529 Plan account(s) by charging
a monthly fee of up to $6 per account. Fees are taken at the first of each month once the account has
been active for thirty (30) days or more. SavvyFi’s Fee is separate from the annualized fees and
expenses of the Record Keeper and the Custodian, which may include underlying administrative,
investment management, program management, and fund fees (see “Other Fees and Expenses
Incurred by Client” in this item, “Fees and Compensation” for additional information).
SavvyFi reserves the right, in its sole discretion, to negotiate, reduce, or waive the Fee for certain
accounts for any period determined solely by SavvyFi. In addition, SavvyFi may grandfather, reduce, or
waive its fee for the account of some Clients without notice to, or fee adjustment for, other Clients. The
actual fee charged will be specified in each individual Client’s Client Agreement.
As of the date of this Brochure, the Record Keeper and the Custodian’s fees range from 14 basis
points (0.14%) to 16 basis points (0.16%). The fees and expenses of the Record Keeper and the
Custodian can be found in their explanation of fees or program description. SavvyFi reserves the right
to change its Fee, and SavvyFi will promptly notify the Client of any increase or decrease in the Fee
should such change occur. A change in the Fee will be effective for the Client’s SavvyFi account
starting in the next month.
Clients must acknowledge and accept that services similar to those provided by SavvyFi may be
available from other sources at lower costs.
The summary of fees is broken down as follows:

    •   Employer-related Accounts: These fees are based on contract. The fees are paid by the
        employer or the employee, or the fees are split between the employer and employee.
    •   Individual Accounts: All client accounts will be assessed a flat fee of up to $6. Some accounts
        may be grandfathered or assessed lower fees based on individual contracts.
    •   All Accounts:
               • Record Keeper and Custodian Fee: Between 0.14% and 0.16% annual fee (or as
                   specified in the most recent Record Keeper’s Fee Disclosure if different) billed by
                   the Record Keeper – This fee is deducted directly from the Client’s account(s) and,
                   therefore, indirectly affects the Client’s portfolio performance.

Billing of Fees Incurred by Client
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 Employer Related Accounts
 SavvyFi’s Online Software fees incurred by the Client in connection with SavvyFi’s Services are generally
 paid through the employer. Direct employee billing is uncommon and generally limited to legacy users
 or edge cases. This fee arrangement is only in place when the employee signs up for SavvyFi’s services
 through the Client’s employer. SavvyFi’s primary billing model for new employer clients is annual
 prepaid employer contracts. A smaller set of legacy employer clients are billed on a per-employee-per-
 month (PEPM) basis. SavvyFi does not offer any other method of fee billing or fee collection to Clients
 and does not deduct fees directly from Client’s 529 Account.

 Depending on the employer, some employee-paid fee accounts may be treated as Individual Accounts
 (see below).

 For the ReNEW Program, SavvyFi, inclusive of its supervised persons, does not receive compensation
 related to the sale of investment products or securities, nor does it receive any compensation from the
 Record Keeper or the Custodian in which the Client invests.

 SavvyFi receives compensation from the program sponsor (e.g., Western Governors University) for
 providing technology platform, administrative, and program support services. SavvyFi does not receive
 compensation directly from individual participants.

Individual Accounts
Fees incurred by the Client in connection with SavvyFi’s Services will be taken the first of each month.
Fees will be automatically deducted from the bank account linked to SavvyFi’s Online Platform.

Other Fees and Expenses Incurred by Client
SavvyFi’s Fee is separate from the fees and expenses of the Record Keeper and the Custodian. The
separate fees and expenses of the Record Keeper and the Custodian (“Plan Fees”) are charged
through an annual asset-based fee, which may be composed of administrative, program management,
investment management, fund, broker- dealer, and record-keeping costs. As of the date of this
Brochure, annualized Plan Fees for the Enrollment Date Option range from 14 basis points (0.14%) to
16 basis points (0.16%) of assets in the Account(s). Plan Fees are deducted directly from the Client’s
Account(s) and, therefore, indirectly affect the Client’s portfolio performance. Clients should refer to
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Types of Clients
 SavvyFi provides Services to employers, individuals, and trusts in the United States and residence of the
 United States only. SavvyFi’s Services are limited to advice in connection with the Client’s 529 Plan. If a
 Client is excluded from account ownership by the Record Keeper, that Client will also be ineligible for
 SavvyFi’s Services.
 As of the date of this Brochure, Clients have no minimum account balance required to open or
 maintain a SavvyFi account.

Methods of Analysis, Investment Strategies, and Risk of Loss
 Description of Analysis Methods and Investment Strategies
 Because of the many variables that can factor into choosing an education savings plan and investment
 option, SavvyFi believes that a simplified enrollment process will allow Clients to start saving earlier and
 that a substantially more complex enrollment process would be too burdensome for Clients, ultimately
 resulting in a delayed decision to open the Client’s education savings account where they otherwise
 would not intend to delay the decision. As such, SavvyFi has simplified the enrollment process for
 Clients by selecting the Record Keeper and using an Enrollment Date Option as defaults for all of its
 Clients.
 SavvyFi is aware of academic and industry research which has demonstrated that the investment
 behavior of households can be influenced by past returns, and that the resulting return- chasing
 behavior can have a significant negative impact on a household’s investment performance.1 To
 minimize the influence of return-chasing behavior, SavvyFi has selected an enrollment date option as
 the default and only investment option in the Investment Plan for all Clients.
 1.   Chien, YiLi. “Chasing Returns Has a High Cost for Investors.” Federal Reserve Bank of St. Louis, April 2014.

 The current Enrollment Date Option automatically allocates the Client’s assets to progressively
 decreasing levels of expected risk based on the Beneficiary’s age. The investment options, asset
 allocation, or underlying funds in the Enrollment Date Option are managed by the Custodian’s Record
 Keeper’s program administrators and/or investment managers. SavvyFi does not represent or offer any
 assurance that the asset allocations of the Enrollment Date Option will maximize a Client’s returns,
 minimize risk, or be the appropriate allocation in all circumstances for every investor who has a
 particular time horizon or risk tolerance. Clients should acknowledge and be prepared to bear the risk of
 substantial loss of their original investment when investing. By selecting the appropriate age range in
 the Enrollment Date Option, the Client is indicating his or her risk tolerance for the 529 Plan account(s).

 SavvyFi does not represent that its analysis of or selection amongst 529 Plans incorporates any specific
 Client’s, or Client type’s, financial situation, or circumstances. SavvyFi’s evaluation leading to the
 selection of the current Record Keeper’s Enrollment Date Option as the default for all Clients’
 Investment Plans generally considered the following factors:

      •
     Availability of enrollment date investment options;
      •
     Returns of enrollment date investment options;
      •
     Appropriateness of enrollment date for K-12 education or Student Loan repayment needs;
      •
     Program administrators, investment managers, program managers, and record keepers of 529
     Plans;
   • Total annualized fees of 529 Plans;
   • Ability of the 529 Plan to integrate with SavvyFi’s Online Software;
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    •   Minimums to open a 529 account;
    •   Minimum contributions to a 529 account;
    •   Annual 529 account maintenance fees.
Student’s projected costs of college are determined based on a historical analysis of net price for
student’s ages 1-18. The Student’s projected future costs of college are determined based on an
analysis of historical net price growth and the Student’s expected college enrollment date. These
projections are estimates and assume that the Student will be listed as a dependent of the Client on
the Student’s Free Application for Federal Student Aid (“FAFSA”). If this is not the case, the Student’s
projected costs of college may not be a reasonable approximation.

Material Risks of Method of Analysis
The following risks of SavvyFi’s method of analysis may not be all-inclusive but should be considered
carefully by a prospective Client before retaining SavvyFi’s Services.

    •   Limited Investment Direction – SavvyFi offers only one 529 Plan program, with one
        custodian’s record keeper and one investment option to simplify the enrollment process for
        Clients. SavvyFi does not allow Clients to select their own investments because the investments
        recommended by SavvyFi are part of the overall Investment Plan for the Client.
    •   No Suitability Determination – SavvyFi makes no representations regarding the suitability of the
        Investment Plan made available through SavvyFi’s Services for any particular Client. When
        using SavvyFi’s services to save for K-12 expenses or repayment of student loans, the time
        horizon of the Algorithms set forth in the Enrollment Date program is not focused on these
        investment objectives. Other types of investments and other types of education savings
        vehicles may be more appropriate depending on a potential Client’s financial situation and
        circumstances. The Client’s Investment Plan does not, nor is it intended to, constitute legal or
        tax advice. Clients are encouraged to consult their legal or tax advisor about the impact of the
        Investment Plan on the Client’s individual situation.
    •   Eligibility for Financial Aid and Other Noneducational Benefits – Being the owner or
        beneficiary of a 529 account may adversely affect financial aid and other federal and state
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