Swan Global Management LLC

Item 5 Fees and Compensation

      1. Swan Global Management, LLC receives management fees for being sub-adviser of the Swan mutual
         funds and ETFs, the Pacer Swan SOS ETFs, and to Swan Capital Management, LLC. Please see the
         Swan prospectuses for complete and detailed presentation of fees. A prospectus may be obtained by
         calling the firm at (970) 382-8901 or referencing the websites at www.swandefinedriskfunds.com and
         etfs.swanglobalinvestments.com. The mutual funds are distributed by Northern Lights Distributors,
         LLC, and the ETFs Northern Lights and by Foreside Fund Services, LLC, members FINRA/SIPC.
         Northern Lights Distributors, LLC, Foreside Fund Services, LLC and Swan Global Management, LLC
         are not affiliated.

      2. Swan Global Investments, LLC, an affiliated adviser, receives management fees for being the adviser
         for SMA accounts and services to the other affiliated Swan companies, including Swan Capital
         Management, LLC and Swan Global Management, LLC. Swan Global Management may also act on
         its own and receive fees for advisory services offered. Please reference Item 10 for more information
         on our affiliates.

      3. Swan Global Management, LLC charges a negotiable asset-based fee ranging between 1.00%

          and 2.00% per annum based on an annualized percentage of total monies invested, as authorized
          per client agreement, applied on a daily, monthly, or quarterly basis. On rare occasions, fee
          paying arrangements may differ from those stated above. While we believe our standard fees are
          reasonable, services similar to those provided by us may be available for lower fees from other sources.
          The fees that we charge for investment advisory services are specified in the agreement between us
          and each individual client.

      4. Swan's management fees are paid daily by one custodian and monthly or quarterly by the others
         in arrears. These are paid by the qualified custodian that is holding the client’s funds and securities;
         provided the client supplies written authorization permitting the fees to be paid directly from the
         account. Swan also acts as Sub-Adviser money manager to other Advisers for their clients. In some
         of these relationships, the Adviser prefers to bill the client for Swan and pays Swan the money
         management fee. These Advisers bill in different time cycles, with some in arrears and some in
         advance.

      5. Clients pay brokerage commissions to the custodian/brokerage firm for each transaction including
         the purchase and sale of any exchange traded fund or mutual fund invested in and any and all option
         trades. Swan does not share in any portion of these fees. Additionally, the client pays the exchange
         traded fund expenses and mutual fund fees, which are built into the price of the fund and charged daily
         by the fund company. These additional fees and expenses are described in each fund’s prospectus and
         may include administration, custody, distribution, shareholder servicing, and transfer agency fees. The
         advisory fee also does not cover debit balances or related margin interest or SEC fees or other fees or
         taxes required by law. Swan may also invest client assets in the Swan advised mutual funds. In these
         instances, Swan does not bill the client on any assets invested in the Defined Risk Funds. For
         information on broker practices, please see Item 12, Brokerage Practices.

      6. Wrap Fee Accounts – As stated in Item 4, we participate in several “wrap-fee” accounts programs,
         which are sponsored by unaffiliated investment advisory and/or brokerage Firms (each a “Sponsor”
         and collectively, the “Sponsors”). As a client in such a Program, you should carefully review the
         Sponsor’s Appendix 1 of the Sponsor’s Form ADV, for complete details regarding the Program. As a
         client participating in these Programs, you should be aware that you may be charged various Program
         fees in addition to the advisory fee charged by us. All such fee disclosures will be provided in the
         Program Sponsor’s ADV Part 2A, Appendix 1.

      7. Our clients do not pay fees in advance. Clients may terminate their contract at any time and will
         only pay fees through the end of the day in which they terminate their contract.

      8. Certain Swan supervised persons and related sales personnel may also be associated with Northern
         Lights, an un-affiliated limited purpose broker-dealer, and in that capacity may engage in marketing
         or selling activities with respect to shares in our affiliated mutual funds or to solicit our separate
         account business to other registered investment advisers. Supervised persons and related sales
         personnel may be internally compensated for successful marketing or selling activities with respect to
         shares in our mutual funds.

Item 7 Types of Clients

    Swan provides investment management services to investment advisors, individuals, institutions, trusts,
    pension plans, corporations and family offices. Swan focuses its services on asset management
    and generally does not provide financial advisory services or financial planning services to clients.
    Swan’s clients include third party investment advisers whereby Swan acts as a sub-advisor money
    manager. In addition, Swan serves as investment adviser to privately placed pooled investment vehicles
    including limited partnerships. Investment advisory clients are not solicited to invest in these vehicles.
    The Firm’s minimum account size is $250,000 which may be waived at the sole discretion of the Firm.