Swan Wealth Advisors LLC

Item 5 Fees and Compensation

    Swan charges a negotiable asset based fee ranging between 0.50% to 1.25% per annum based on an
    annualized percentage of total monies invested, as authorized per client agreement, applied on a daily,
    monthly, or quarterly basis. The fees charged may vary based on the size of the investment account. Sub-
    advised clients have fees that are negotiated between their advisor and Swan and generally follow a similar

    range, although there may be rare instances of lower negotiated fees. 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.

      A. 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.

      B. 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.

      C. 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.

      D. 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.

      E. Swan Capital Management, LLC, our affiliated adviser to our mutual funds and ETFs, receives
      management fees for being adviser of the Swan Funds. Please see the Swan prospectus for complete and
      detailed presentation of fees. A prospectus may be obtained by calling the firm at (877) 896-2590 or
      referencing the website at www.swandefinedriskfunds.com.

      F. Swan Global Management, LLC, an affiliated adviser, receives management fees for being sub-adviser
      to the other affiliated Swan companies, including Swan Capital Management, LLC and Swan Global
      Investments, 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.

      G. 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 the 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. T h e Swan affiliates focus their services on mostly
    asset management and generally does not provide financial advisory services or financial planning
    services to clients. Swan Wealth Advisors, LLC is intending to begin offering more advisory services and
    family office 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. Swan asset management offerings, as detailed further in Item 1, include mutual funds,
    ETFs, Overlay type SMAs, sub-advised SMAs, and direct SMAs.

    Swan Wealth Advisors does not pursue singular investment strategies and does not utilize commissioned
    products. Swan crafts a wealth management and wealth protection strategy to fit client unique
    circumstances. Swan always puts wealth protection first and the client will have access to financial resources
    not often available to individuals in the general market.

    Swan Wealth Advisors is composed of specialists who work as a team to craft an individualized strategy for
    clients and client families. One of the most important things is that Swan is an independent advisor, so Swan
    has no outside interests and no affiliations with special interest groups. Swan Wealth Advisors focus is the
    client. Swan Wealth Advisors is affiliated with the Swan companies and the Swan Defined Risk Strategy,
    recommend the use of the Swan product and service offerings, but do not insist on the use of them for client
    specific needs.

    Each client is served by a dedicated team, led by a seasoned wealth management expert. Clients may call
    any member of the service team, at any time, with questions. The client wealth management team represents
    several areas of expertise, including investment management, tax planning, estate and gift planning, risk
    management and insurance, cash management and special services. Swan leverages decades of experience to
    assemble a core group of service providers and coordinate their roles. Swan has found this approach assures
    strategic wealth management and unparalleled service.