Secured Retirement Advisors LLC

Fees and Compensation - Item 5

 Financial Planning Service Fees
 Our firm may charge a fixed fee for broad-based financial planning services, which ranges between $500 - $25,000
 depending upon the complexity and scope of the plan, your financial situation, and your individual objectives. In
 no event will we require a payment of $1,200 in fees, six or more months in advance.

 If you only require advice on a single aspect of your finances, we offer modular financial planning/general
 consulting services on an hourly basis. Our hourly rate for such services is $500 per hour and is negotiable
 depending on the scope and complexity of the plan, your specific situation, and your investment goals and
 objectives. These fees are payable as invoiced.

 If the disclosure brochure - Part 2 of the Form ADV - is not delivered to you within 48 hours prior to you entering
 into the financial planning agreement, you may terminate the agreement within five business days of the date of
 acceptance without penalty. If you received the disclosure documents 48 hours in advance or if the five-day grace
 period has expired, either party may terminate the agreement upon written notice to the other party. You will
 incur a pro rata charge for bona fide financial planning and/or consulting services rendered prior to such
 termination. Any pre-paid unearned fees will be refunded to you on a pro rata basis. If you are unhappy with the
 consultation or financial planning process, you may request a refund of our fee within the first 180 calendar days
 following the date of entering into the investment advisory agreement.

 Portfolio Management Services
 Our Management Fee (or annual fee) for portfolio management services is billed and payable monthly, in arrears,
 based on the daily average balance of the account. Our fees will be assessed pro rata in the event the portfolio
 management agreement is executed at any time other than the first day of a calendar month. On an annualized

Secured Retirement Advisors, LLC
Form ADV Part 2A

 basis, our fees for portfolio management services, subject to negotiation, are based on the following tiered fee
 schedule:

 Billable Assets Under Management                      Annualized Fee
 First $250,000                                        1.50%
 Next $750,000                                         1.25%
 Next $1,500,000                                       1.00%
 Next $2,500,000                                       0.75%
 Next $5,000,000                                       0.50%
 Over $10,000,000                                      Negotiable

 Legacy clients may be subject to a different fee schedule and fee payment arrangement. Such fees and payment
 arrangement are listed in the advisory agreement signed by both the client and the firm. We reserve the right to
 charge a fee of $100 per year per account to maintain an account; however, in some cases this fee may be waived.

 The daily average balance is calculated by adding the daily account balances for the month and dividing it by the
 number of days. This amount may not be the same as the monthly ending account balance. The fee for partial
 months is calculated by multiplying the daily average balance by the annual fee percentage, dividing it by 365,
 then multiplying the total by the number of days in the month. The fee for full months is calculated by multiplying
 the daily average balance by the annual fee percentage divided by 12.

 For example, a client with $2,000,000 in assets under management on the last day of the month, will pay a fee
 of $1,927.08. This fee is calculated using the following methodology:

 ($250,000 x 1.50%) ÷ 12 = $3,750 ÷ 12 = $312.50
 ($750,000 x 1.25%) ÷ 12 = $9,375 ÷ 12 = $781.25
 ($1,000,000 x 1.00%) ÷ 12 = $10,000 ÷ 12 = $833.33
 Total Fee: $1,927.08

 The fees charged are calculated as described above, and are not charged on the basis of a share of capital gains
 upon, or capital appreciation of, the funds, or any portion of your funds. We do not charge a fee on cash or cash
 equivalents, such as CDs, money market accounts or money market funds. However, for the purpose of
 calculating the Management Fee, the daily account balances will include any margin debit balance which will
 increase the daily account balance and increase your Management Fee.

 We reserve the right to maintain courtesy accounts that do not incur Management Fees and to exclude certain
 positions from being included in the account balance for purposes of calculating the Management Fee. Also, we
 do not include the value of your insurance products when determining the Management Fee.

 At our discretion, we may allow accounts of members of the same household to be aggregated for purposes of
 determining the advisory fee. We may allow such aggregation, for example, where we service accounts on behalf
 of your children, individual and joint accounts for a spouse, and other types of related accounts. This
 consolidation practice is designed to allow you the benefit of an increased asset total, which could potentially
 cause the accounts to be assessed a reduced advisory fee based on the breakpoints available in our fee schedule
 as stated above.

 The Management Fee is exclusive of, and in addition to any applicable securities transaction and custody fees,
 and other related costs and expenses described in Item 5 (hereinabove), which you may incur. However, we will
 not receive any portion of these commissions, fees and costs.

Secured Retirement Advisors, LLC
Form ADV Part 2A

 Margin in Advisory Accounts. The use of margin in your Account is permitted. Borrowing against your account
 gives you access to cash and/or the ability to purchase additional securities. You should be aware that a margin
 debit balance increases your Account’s daily account balance, which in turn increases the amount of
 Management Fee you pay. It is a conflict of interest for us to recommend that you borrow on margin in your
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Types of Clients - Item 7

 We offer investment advisory services to individuals, pension and profit sharing plans, trusts, estates, charitable
 organizations, corporations, and other business entities.

 In general, we require a minimum of $250,000 to open and maintain an advisory account. At our discretion, we
 may waive this minimum account size. For example, we may waive the minimum if you appear to have significant
 potential for increasing your assets under our management. We may also combine account values for you and
 your spouse and your children and other types of related accounts to meet the stated minimum. We do not
 charge a fee on cash or cash equivalents. We reserve the right to charge a fee of $100 per year per account to
 maintain an account; however, in some cases this fee may be waived.

 We reserve the right to terminate your account if it falls below a minimum size, which, in our sole opinion, is too
 small to effectively manage.

                       Methods of Analysis, Investment Strategies and Risk of Loss - Item 8

 Our investment strategies and advice may vary depending upon your specific financial situation. As such, we
 determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon,
 financial horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and
 guidelines may affect the composition of your portfolio.

Secured Retirement Advisors, LLC
Form ADV Part 2A

 We may use one or more of the following methods of analysis when providing investment advice to you:

     •    Fundamental analysis is a method of evaluating a company or security by attempting to measure its
          intrinsic value. In other words, trying to determine a company’s or a security’s true value by looking at
          all aspects of the business, including both tangible factors (e.g., machinery buildings, land, etc.) and
          intangible factors (e.g., patents, trademarks, “brand” names, etc.). Fundamental analysis also involves
          examining related economic factors (e.g., overall economy and industry conditions, etc.), financial
          factors (e.g., company debt, interest rates, management salaries and bonuses, etc.), qualitative factors
          (e.g., management expertise, industry cycles, labor relations, etc.), and quantitative factors (e.g., debt-
          to-equity and price-to-equity ratios). The end goal of performing fundamental analysis is to produce a
          value that an investor can compare with the security's current price in hopes of determining what sort
          of position to take with that security (underpriced = buy, overpriced = sell or short). This method of
          security analysis is considered the opposite of technical analysis. Fundamental analysis is about using
          real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks,
          this method of valuation can be used for just about any type of security.

      • Technical Analysis – Technical analysis is a technique that relies on the assumption that current market
        data (such as charts of price, volume, and open interest) can help predict future market trends, at least
        in the short term. It assumes that market psychology influences trading and can predict when stocks will
        rise or fall. Technical trading models are mathematically driven based upon historical data and trends of
        domestic and foreign market trading activity, including various industry and sector trading statistics
        within such markets. Technical trading models, through mathematical algorithms, attempt to identify
        when markets are likely to increase or decrease and identify appropriate entry and exit points. The
        primary risk of technical trading models is that historical trends and past performance cannot predict
        future trends, and there is no assurance that the mathematical algorithms employed are designed
        properly, updated with new data, and can accurately predict future market, industry, and sector
        performance.

 We may also obtain research from unaffiliated third parties. Prior to engaging the services of any unaffiliated
 third party research provider, SRA will conduct an informal due diligence review of the research provider.

 We may use one or more of the following investment strategies when advising you on investments:

      • Long Term Purchases – securities purchased with the expectation that the value of those securities will
        grow over a relatively long period of time, generally greater than one year. Using a long-term purchase
        strategy generally assumes the financial markets will go up in the long-term which may not be the case.
        There is also the risk that the segment of the market that you are invested in or perhaps just your
        particular investment will go down over time even if the overall financial markets advance. Purchasing
        investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized
        in the short-term in other investments.

      • Short Term Purchases – securities purchased with the expectation that they will be sold within a
        relatively short period of time, generally less than one year, to take advantage of the securities' short-
        term price fluctuations. Using a short-term purchase strategy generally assumes that we can predict
        how financial markets will perform in the short-term which may be very difficult and will incur a
        disproportionately higher amount of transaction costs compared to long-term trading. There are many
        factors that can affect financial market performance in the short-term (such as short-term interest rate
        changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer periods of
        times.
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