Strategic Family Wealth Counselors LLC

Item 5. Fees and Compensation
         SFWC offers its services on a fee basis, which includes fixed fees and fees based upon assets under
         management.

         Financial Planning Fees

         SFWC charges a fixed and/or hourly fee for the firm’s standalone financial planning services. These fees
         are negotiable, but generally range from $2,500 to $1,000,000 on a fixed fee basis.             In certain
         circumstances the firm will also negotiate a fee based upon the assets under advisement and/or the
         client’s net worth.   The fee is largely determined by the level and scope of the services and the
         professional engaged to render them. If the client engages SFWC for additional investment advisory

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         Strategic Family Wealth Counselors, L.L.C. Disclosure Brochure

         services, SFWC may offset all or a portion of its fees for those services based upon the amount paid for
         the financial planning services.

         Prior to engaging SFWC to provide financial planning services, the client is required to enter into a written
         agreement with SFWC setting forth the terms and conditions of the engagement. Generally, SFWC
         requires one-half of the financial planning fee (estimated hourly or fixed) payable upon entering the
         written agreement. The balance is generally due upon delivery of the financial plan or completion of the
         agreed upon services.

         Investment Management and Wealth Management Fees

         SFWC provides investment management services for an annual fee based upon a percentage of the
         assets under management.           The annual fee varies between 0.10% and 1.50% of the assets being
         managed by SFWC, depending upon the size of a client’s portfolio and the investment management
         services to be rendered. This fee is prorated and charged quarterly, in advance, based upon the market
         value of the assets on the last day of the previous quarter. Certain of the firm’s financial planning
         services may be included under this annual asset-based fee, as part of SFWC’s wealth management
         offering.

         SFWC’s annual fee is exclusive of, and in addition to brokerage commissions, transaction fees, and other
         related costs and expenses which are incurred by the client. SFWC does not, however, receive any
         portion of these commissions, fees, and costs.

         The Firm includes cash in a client’s account in determining the valuation for billing purposes. The Firm
         may, in its sole discretion, not include cash in determining the fee, especially where a client has a high
         percentage of cash for reasons other than the Firm's investment management decision. SFWC, in its
         sole discretion, will negotiate to charge a lesser management fee based upon certain criteria (i.e.,
         anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be
         managed, related accounts, account composition, pre-existing client, account retention, pro bono
         activities, etc.).

         If a valuation for private securities is not available through the custodian, the Firm will typically rely on the
         valuation provided by the issuer.       Because valuations may only be provided periodically (including
         monthly, quarterly or even annually), the Firm can be billing on a valuation that would be different if
         updated. That valuation can be higher or lower depending on the increase or decrease in value of the
         private investment.

         Clients are advised that a conflict of interest exists for the firm to recommend that clients engage SFWC
         for additional services for compensation, including rolling over retirement accounts or moving other assets
         to the firm’s management. Clients retain absolute discretion over all decisions regarding engaging the
         firm and are under no obligation to act upon any of the recommendations.

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         Fees Charged by Financial Institutions

         As further discussed in response to Item 12 (below), SFWC generally recommends that clients utilize the
         brokerage and clearing services of Schwab Advisor Services (“Schwab”) and Fidelity Brokerage Services
         LLC (together with affiliates, “Fidelity” and together with Schwab or any other recommended broker-
         dealer “the Custodians”) for investment management accounts.

         SFWC only implements its investment management recommendations after the client has arranged for
         and furnished SFWC with all information and authorization regarding accounts with appropriate financial
         institutions. Financial institutions include, but are not limited to, Fidelity, Schwab, any other broker-dealer
         recommended by SFWC, broker-dealer directed by the client, trust companies, banks etc. (collectively
         referred to herein as the “Financial Institutions”).

         Clients incur certain charges imposed by the Financial Institutions and other third parties such as fees
         charged by Independent Managers, custodial fees, brokerage commissions and transaction fees, charges
         imposed directly by a mutual fund or ETF in the account, which are disclosed in the fund’s prospectus
         (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials,
         transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts
...

Item 7. Types of Clients
          SFWC provides its services to individuals, pension and profit sharing plans, trusts, estates, charitable
          organizations, corporations and business entities.

          Minimums Imposed By Independent Managers

          SFWC does not impose a minimum portfolio size or minimum annual fee. Certain Independent Managers
          may, however, impose more restrictive account requirements and varying billing practices than SFWC. In
          such instances, SFWC may alter its corresponding account requirements and/or billing practices to
          accommodate those of the Independent Managers.

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          Strategic Family Wealth Counselors, L.L.C. Disclosure Brochure