SDR Investment Management Inc

Item 5 - Fees and Compensation

SDR Investment Management, Inc. d/b/a Siler Wealth Management manages client investment accounts for an
asset-based fee calculated as a percentage of assets under management. Fees are determined by the size and
complexity of each account and are outlined in the Investment Advisory Agreement applicable to that account.
Advisory fees are withdrawn directly from client accounts, in accordance with written authorization provided
by each client. Fees begin to accrue once assets are deposited into the advisory account, and clients receive an
invoice reflecting the amount deducted.

Most advisory fees are calculated as an annual percentage and are billed quarterly in advance at the start of each
billing period. Fees are based on the account’s asset value as of the last business day of the previous quarter.
Clients may cancel their advisory agreement without penalty within five (5) business days of signing. After that,
written notice is required to terminate the relationship, with termination effective on the last day of the month in
which notice is received. If the agreement is terminated after ninety (90) days, clients will receive a prorated
refund for the unearned portion of any prepaid fee.

Accounts utilizing the services of Simplicity Wealth are billed monthly in arrears in accordance with
Simplicity’s billing process. The average daily balance is typically used to determine account value for billing
purposes. Clients may terminate their agreement with thirty (30) days’ written notice. Because these fees are
billed in arrears, no refund policy applies. Fees for new accounts and for mid-period cash flows (contributions
or withdrawals) are prorated based on the timing of the transaction. Clients may terminate their accounts
without penalty within five (5) business days of signing the client agreement.

Investment Advisory Fee Schedule

The Firm’s discretionary investment management services are billed according to the following schedule:

       Less than $250,000             1.85%;
       $250,001-$500,000              1.60%;
       $501,000-$1,000,000            1.35%;
       $1,000,001-$2,000,000          1.15%;
       $2,000,001-$3,000,000          .90%;
       $3,000,001 & Above             .75%;

Advisory fees are negotiable at the advisor’s discretion, and a signed and dated Investment Advisory
Agreement reflecting the agreed-upon rate must be on file.

Fees exceeding 2.00% are considered above industry standards, and comparable services may be available
from other investment advisers at a lower cost.

Estate Planning Services

The flat fee schedule for Estate Planning Services is as follows:

       • Individual Will – $199
       • Joint Will – $299
       • Individual Trust – $499
       • Joint Trust – $599

Estate planning services are billed at $300 per hour.

For ongoing estate planning support, depending on the complexity of needs, an additional 0.15% to 0.25% may be
applied to the annual management fee, as disclosed in the SDR Investment Advisory Agreement. Management
fees are deducted directly from client accounts, and an invoice is provided to all clients billed during the
quarter.

Social Security Consulting and Financial Planning Services

The Firm offers Social Security consulting and analysis services to help clients evaluate benefit strategies and
determine optimal claiming decisions. These services are billed separately at $250 per hour and are
independent of ongoing advisory or financial planning fees.

The Firm also provides financial planning on a case-by-case basis for individuals who are not advisory clients.
These services are billed at $250 per hour, with payment due upon completion of services.

Other Fees and Expenses

Certain supervised persons of the Firm may sell insurance products and receive commissions in connection with
those transactions. Clients are not obligated to purchase insurance products through the Firm. The potential
receipt of commissions presents a conflict of interest, which the Firm mitigates by disclosing all compensation
in advance and maintaining a fiduciary duty to act in each client’s best interest.

Clients investing in mutual funds—whether load or no-load—may incur two layers of fees: one paid to the Firm
for advisory services and another management fee charged by the mutual fund itself, which is reflected in the
fund’s share price.

Item 7 - Types of Clients

SDR Investment Management, Inc. d/b/a Siler Wealth Management provides investment advisory, financial
planning, and consulting services to a diverse range of clients, including individuals, families, trusts, estates,
charitable organizations, pension and profit-sharing plans, 401(k) plans, and business entities.

The Firm does not impose a minimum account size to open or maintain an advisory relationship. However,
certain custodial platforms or third-party managers utilized by the Firm may establish their own minimum
account requirements. The Firm reserves the right to accept or decline new accounts based on factors such as
account size, complexity, and the client’s overall relationship with the Firm.