Spectrum Investment Advisors Inc

Item 5 – Fees and Compensation
A. Fees For Services.

Plan Consulting Services Fees

Clients compensate SIA for Plan Consulting Services, including clients in the Spectrum Pathway Pooled
Employer Plan, based upon the total market value of assets in a client’s plan on the last day of the
previous three- month billing period and are payable in arrears. The initial fee due is pro-rated to the end
of the calendar quarter in which the agreement is signed. Thereafter, fees are calculated and due on a
quarterly basis. In the event the agreement is terminated prior to the last day of any quarter, all fees due
to SIA are pro-rated to the date of termination and are due promptly after termination.

Fees are negotiable and generally are billed by SIA directly to the custodian, based on client approval,
and are deducted from the client’s plan account. Upon client direction, SIA may bill the plan sponsor
directly.

Generally, SIA’s fee schedule for Plan Consulting Services is as follows:

        Account Size                    Annual Fee
        First $5,000,000                0.40%
        Next $5,000,000                 0.30%
        Next $10,000,000                0.25%
        Balance                         0.20%

For plans with a market value of less than $5 million, fees generally begin at 0.50% of the plan’s market
value. Effective March 2026, all new plans with a market value of less than $5 million are charged a
minimum quarterly fee of $1,750.

In some instances, SIA may charge clients for its services on a flat fee basis or on a per participant basis
based on negotiations with a particular client. Further, in some instances, SIA may consider the number of
retirement plans advised for a particular client when negotiating fees. These fees are negotiable and
billed quarterly in arrears.

As described in Item 4, if a plan chooses to utilize SIA financial wellness services, additional fees paid to
SIA will apply and are negotiated on a case-by-case basis.

Clients may terminate the agreement upon thirty (30) days’ advance written notice to SIA.

SIA reserves the right to change fees for SIA’s services upon sixty (60) days’ advance written notice.

Wealth Management Services Fee

Clients compensate SIA for investment advisory services on a calendar quarterly basis in arrears, in
accordance with the fee schedule described below. SIA may negotiate fees based on account size and
other factors deemed important by SIA. SIA retains the right to amend the schedule of fees upon sixty
(60) days’ advance written notice to the client. The fee excludes all brokerage and custodian costs, which
are separately billed to the client by the respective broker/custodian.

SIA’s fee schedule for Wealth Management Services is as follows:

Asset Based Fee

         Account Size                      Annual Fee
         Up to $500,000                    1.00%
         $500,001 to $1,000,000            0.80%
         $1,000,001 to $2,000,000          0.60%
         Over $2,000,000                   0.50%
Different fee schedules may be in effect for certain clients who opened an account prior to July 18, 2013.
All accounts are subject to a minimum annual fee of $2,000.

Clients may terminate the agreement upon thirty (30) days’ advance written notice to SIA.

SIA also manages accounts for employees and friends and family members of SIA employees at a
discounted fee rate.

Investment Consulting Services Fee

Clients compensate SIA for investment consulting services on a calendar quarterly basis in arrears, in
accordance with the fee schedule described below. SIA may negotiate fees based on account size and
other factors deemed important by SIA. SIA retains the right to amend the schedule of fees upon sixty
(60) days’ advance written notice to the client. The fee excludes all investment management, brokerage
and custodian costs, which are separately billed to the client by the respective investment adviser and/or
broker/custodian.

SIA’s fee schedule for Investment Consulting Services is as follows:

         Account Size                      Annual Fee
         Up to $5,000,000                  0.30%
         Next $5,000,000                   0.25%
         Next $5,000,000                   0.20%
         Next $5,000,000                   0.15%
         Balance                           0.10%

Financial Planning Services Fee

SIA offers standalone financial planning services to clients who do not utilize our investment
management services. Clients using this service will be charged a flat fee based on the complexity of the
planning to be performed.

General Fee Information

For all accounts, fees are calculated on the basis of the market value of the assets maintained in the
account, including any balances in the account held in a money market fund, and are payable quarterly.
Fees are billed in arrears. The initial fee is charged in arrears on a pro rata basis from the date of
inception of services through the end of the first calendar quarter in which the account is open.
Thereafter, fees are payable quarterly based upon the market value of assets on the last calendar day of
the previous quarter. SIA may, at its discretion, aggregate the value of the account with the value of other
client-related accounts for fee calculation purposes. All assets deposited to the account during any quarter
will be charged a prorated quarterly fee based upon the amount deposited and the number of days services
were provided to that amount in the quarter. Upon contract termination, clients are obligated to pay SIA
all fees earned to date of termination.

In addition to SIA’s advisory fee for its services, certain investments such as, ETFs, mutual funds, private
funds, BDCs, CITs and REITs, in which a client’s assets are invested also charge their own
advisory/management fees and other expenses which are described in the investment’s disclosure
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Item 7 – Types of Clients/Minimum Account Size
SIA specializes in assisting institutional clients in establishing 401(k) pension, profit sharing plans and
other retirement plans and in monitoring investments in the plans. SIA offers wealth management and
consulting services to individuals, trusts, estates, corporations and other types of entities. SIA also
manages accounts for employees and friends and family members of SIA employees.

SIA also manages a proprietary wealth management account invested in no-load mutual funds and ETFs
that are also recommended to clients. SIA does not consider this proprietary account to be a client
account. This proprietary account may be included in an ETF block order along with client trades when
SIA determines: 1) no client is harmed by the proprietary account participating in the block order; and 2)
the proprietary account is not unfairly advantaged by trading along with client accounts.

SIA maintains a Code of Ethics and Personal Trading policy designed to assist in addressing conflicts of
interest should they arise. Please see Item 12 for a discussion of SIA’s trading practices.

Generally, the firm does not impose a minimum account size; however, it does impose a minimum
account fee as disclosed in Item 5 above.