Strategic Point Investment Advisors LLC

Item 5 – Fees and Compensation

INVESTMENT MANAGEMENT SERVICES FEE StrategicPoint Investment Advisors’ (“SPIA”) annual investment
management fee for investment management services shall be based upon a percentage (%) of the market value
of the assets under management in accordance with the following fee schedule (the “Fee Schedule”):

Assets under Management (End-of-Quarter)        Quarterly Fee Percent              Annual Fee Percent*

Under $500,000                                   .3125%                              1.25%
$500,000-$1,000,000                              .2500%                              1.00%
$1,000,001-$1,500,000                            .2125%                              0.85%
$1,500,001-$2,000,000                            .1875%                              0.75%
$2,000,001-$3,000,000                            .1500%                              0.60%
$3,000,001-$5,000,000                            .1250%                              0.50%
Over $5,000,000                                  Negotiable                          Negotiable

* This is a tiered or breakpoint fee schedule, such that the entire portfolio is charged the same investment management fee. For
example, a client with $750,000 of assets under management would pay 1.00% on an annual basis and a client with $1,100,000 of
assets under management would pay .85% on an annual basis.

SPIA fees are payable quarterly in arrears based on the aggregate net value of the assets in the accounts, valued
as of the last business day of the calendar quarter as determined by third-party sources. SPIA may maintain cash
and cash equivalent positions in the accounts to ensure the proper portfolio allocation, to provide a buffer for
market volatility and to provide liquidity for withdrawals from the accounts. All such cash and cash equivalent
positions, not including accrued and unpaid interest, will be included in assets under management for purposes
of the investment management fee, unless otherwise agreed to between SPIA and client. For the initial quarter,
the investment management fee shall be calculated in arrears on a pro rata basis based on the number of days
that services are provided. SPIA reserves the right, in SPIA’s discretion, to prorate the investment management
fee for significant contributions during a calendar quarter. In the event that the services are terminated during a
calendar quarter, the investment management fee shall be calculated in arrears on a pro rata basis based on the
number of days that services are provided, and any earned, unpaid fees will be due and payable.

Clients who pay our investment management fees via debit of their accounts authorize the custodian to disburse
our investment management fee to us upon our instruction to the account custodian. We also permit clients to
pay our investment management fee by check or credit card (via PayPal). SPIA shall provide clients with an
invoice reflecting the amount of any fees due for a given period while at the same time providing such notice to
the custodian. The amount deducted from the accounts for any investment management fee will also be shown
as a disbursement on any account statement given to the client by the custodian. The invoice will show the
amount of the investment management fee, how it was calculated and the value of the assets on which the
invoice was based. Client agrees to inspect promptly all invoices, and to promptly notify SPIA in writing
concerning any complaint or objection.

SPIA generally requires a minimum of $250,000 of assets under management for each client relationship.

The standard investment management fee shown in our Fee Schedule is subject to negotiation between SPIA and
the client. SPIA from time to time agrees to discount its fees and agrees to payment arrangements different from
our standard fee arrangements. In addition, existing advisory clients are subject to legacy fee arrangements that
are lower than the current standard fee schedule. Accordingly, while we strive to be consistent, fees vary from
client to client based on a number of factors, including, but not limited to, the type and size of account, the
services provided to the account, the client's other accounts with SPIA, the accounts of the client's family with
SPIA, the expectation that the client will add additional funds to their account, account composition or SPIA's
overall assessment of the client relationship. Certain fees are waived for SPIA employees and are waived or
discounted for certain family members or friends of employees.

Fees charged for separately managed accounts and the FMAX platform (“Program Fee”) shall be in addition to
SPIA’s IMS fee. Separately managed accounts establish and maintain their own separate billing processes over
which we have no control. In addition to the separately managed account fees, the FMAX Platform fees range
from 12 bps to 22 bps (0.12% to 0.22%) based on the dollar amount of the individual account. There is a
minimum annual per-account FMAX Platform fee of $50. The Program Fee is expressed on your custodial
statement. Clients who select the FMAX program will also receive FIWA’s Form ADV Part 2A, which provides
greater detail regarding the program sponsor. The Program Fee and any other fees are outlined in the Statement
of Investment Selection (SIS) that is provided to you prior to investing. The Program Fee is calculated as an
annual percentage of assets based on the market value of the account at the end of a calendar quarter. The
Program Fee is paid to FIWA and covers FIWA’s services associated with FMAX, including access to the FMAX
Platform, the Implementation Manager and the Investment Managers, implementation of a Model, if applicable,
and brokerage, clearing, custody, and other services provided by affiliates of FIWA. The Program Fee calculation
considers cash and cash equivalents. Program Fees are charged on a calendar quarter basis in arrears prorated
...

Item 7 – Types of Clients

SPIA provides services for a variety of clients including individuals, high net worth individuals, and legacy
retirement plan sponsors under ERISA.

SPIA generally requires a minimum of $250,000 of assets under management for each client relationship but
reserves the discretion to waive the minimum on a case-by-case basis.

The FMAX Platform, FIWA, and Sub-Advisors may have minimum account values and fees. Please refer to FIWA’s
and Sub-Advisors’ ADV Part 2A and other disclosure documents for additional information related to minimum
requirements. FMAX, FIWA, and Sub-Advisors minimums are not subject to SPIA’s control and, therefore, may
not be negotiable or waived.