Spectrum Financial Inc

Item 5 – Fees and Compensation

SecurityMaxx℠
This program is marketed directly by officers and employees of Spectrum Financial and through solicitors termed
“Representatives” who may be associated with an advisory firm, brokerage firm or Investment Company affiliated
brokerage firm. A solicitor’s fee is paid to Representatives ranging from 25 basis points of total assets to 50 basis
points of the total fee collected. The fees charged the client for Spectrum Financial services are not increased
because of this arrangement. Often, the Representative is also a licensed salesperson with a broker/dealer. As
such, the representative may receive or have received commissions for the client's initial purchase of the particular
securities and subsequent commissions (sometimes referred to as 12b-1 charges) depending on the program

entered into by the client. Spectrum Financial may also recommend these types of funds to their clients but does
not receive any portion of these commissions under the SecurityMaxx℠ program. All fees paid to Spectrum
Financial for advisory services are separate from the fees and expenses charged to shareholders of mutual fund
shares, variable life, or variable annuity contracts. A complete explanation of expenses charged by the mutual fund
or insurance product contracts is contained in its prospectus and should be reviewed by the client prior to
investing. Since the Representative may also be affiliated with a broker/dealer handling the client's account, there
may be a potential conflict of interest.

QUARTERLY FEE STRUCTURE* RATE%
All available Strategies .48%
Leveraged High Yield     .63%

It is the opinion of the SEC that annual management fees in excess of 2% annualized are considered excessive and
other advisors provide similar services at lower rates. Although Spectrum Financial reserves the right to accept
accounts below $50,000, the recommended minimum account size per contract is $50,000. The 2.5% fee for the
Leveraged High Yield Bond Strategy is due to a higher degree of investment management skill, as well as a
substantial increase in trading activity and operational overhead. Management fees will not be based upon a share
of capital gains or capital appreciation of the funds or any portion of the funds of an advisory client. Fees may be
reduced by Spectrum Financial in certain situations such as, but not limited to employee or representative related
accounts, adjustments due to administrative error, or situations where there is a conflict of interest. In special
circumstances (such as, but not limited to charities, employee/rep accounts, an account over $5 million), Spectrum
Financial reserves the right to waive or negotiate fees. However, generally fees are not negotiated.
The initial fee for the first quarter is based on the total principal amount initially invested. Accounts established in
the middle of the quarter are prorated for the remainder of the quarter. The fee for subsequent quarters is based on
the market value of the client’s account(s) determined at the end of the calendar quarter. The fee for additional
amounts invested is prorated for the remaining portion of the calendar quarter deposit. The quarterly fee calculated
will be deducted by the custodian automatically from client’s cash or money market fund, or an alternative fund
that is associated with the management agreement. A performance report for the 12-month period and the current
holdings will be reported to the client each January.

Termination: The agreement shall remain in effect until either party to the agreement receives written notice
from the other party of their desire to cancel the agreement. The withdrawal of funds from the account being
managed does not constitute giving notice. Non-payment of fees by the client does not serve as notification of
cancellation. Spectrum Financial will make reasonable efforts to inquire whether services are still required by the
client. Spectrum Financial reserves the right to continue managing the account for up to thirty days following the
anniversary date. After the 30-day period, Spectrum Financial has the option to give written notice to the client
terminating the contract. Upon written cancellation of the agreement, all funds will be exchanged to the defensive
(money market) position unless otherwise instructed in the written notification of cancellation. In the event of
termination/cancellation, the refund policy, the percentage fee will be refundable on a monthly pro-rata basis. If
terminated within the first 5 days of the month, no fee is charged for that month. Notwithstanding anything else
with the agreement, the investor has the unilateral, uncontrolled right to terminate the agreement within 5 business
days of its initial execution without penalty. Fees will be refunded in full if the termination of the agreement is
requested within 5 business days of the agreement date.

AssetMaxx℠
AssetMaxx℠ allows clients the ability to choose actively managed funds available within the program and will be
based on their investment objective and risk tolerance. The available funds are sub-advised by two SEC affiliated
advisors.

   1. The Hundredfold Select Alternative Fund: This Fund is sub-advised by Hundredfold Advisors, LLC
      (owned by Simply Distribute Foundation). Spectrum Financial is paid a servicing fee of .25% from the
      distributor Ceros FS, which eliminates additional management fees to Spectrum Financial by the client for
      the AssetMaxx℠ allocation service. Hundredfold Advisors LLC receives donated services from a Spectrum
      Financial’s principal which acts as the Fund’s portfolio manager. In addition, Spectrum Financial also
      provides donated back-office services to Hundredfold Advisors, LLC.
   2. Spectrum Low Volatility Fund, Spectrum Unconstrained Fund, and Spectrum Active Advantage
      Fund (The Spectrum Funds): The Spectrum Funds are sub-advised by Spectrum Financial, Inc.(the
...

Item 7 – Types of Clients
Spectrum Financial provides portfolio management services to individuals, IRAs, corporate pension, profit-
sharing, 401K, charitable institutions, foundations, endowments, and trusts. See account minimum information
under Item 5 above. Spectrum also serves as a sub adviser to three mutual funds.