Symmetry Partners LLC

ITEM 5: FEES AND COMPENSATION

Administrative Services Provided By Technology Vendor
Symmetry has contracted with a third-party vendor to utilize its technology platforms to
support data reconciliation, performance reporting, fee calculation and billing, research,
client database maintenance, quarterly performance evaluations, payable reports, web site
administration, models, trading platforms, and other functions related to the administrative
tasks of managing client accounts. Due to this arrangement, vendor will have access to
client accounts, but vendor will not serve as an investment adviser to our clients. In
addition, vendor provides access to certain third-party reporting databases, which your
financial advisor and Symmetry can access and are responsible for managing. Symmetry
and vendor are non-affiliated companies. Vendor charges our Firm an annual fee for each
account administered by vendor. Please note that the advisory fee charged to the client will
not increase due to the annual fee our Firm pays to vendor. The annual fee is paid from
the portion of the management fee retained by our Firm.

Symmetry Axiom Platform Services
Symmetry charges fees for the administration and management of client accounts. This
fee is separate from and in addition to your investment advisory fee. Symmetry will charge
an annual fee based on the client’s assets under management. Symmetry’s standard
tiered fee schedule, which may, in certain circumstances, be negotiable, is as follows:

     Axiom Platform Fee
     Symmetry Axiom platform fee is assessed as a percentage of assets under
     management and is calculated on a tiered basis. The annual fee schedule begins at
     0.35% and decreases to as low as 0.05%, depending on the total amount of assets
     managed on the platform. When utilizing our Panoramic Mutual Funds, the annual
     fee schedule begins at 0.15% and decreases to as low as 0.05%.

     Product Fees
     We offer a variety of investment products and portfolio strategies, including ETF
     portfolios, separately managed accounts (“SMAs”), factor-based strategies,
     ESG/SRI-focused portfolios, alternative strategies, and fixed income portfolios. Fees
     for these products are assessed as a percentage of assets under management and
     generally range from 0.15% to 0.30% annually, depending on the specific product,
     strategy, and services provided.

     Certain ETF portfolios and fixed income strategies are offered at the lower end of this
     range, while SMAs and sector momentum or factor-focused strategies may be
     offered at the higher end. All fees are negotiable and are fully disclosed to clients
     prior to engagement through client agreements and other required disclosures.

Model Portfolios Fees
Symmetry receives compensation from sales of the Symmetry ETFs that are included in
select Model Portfolios. As a result, Symmetry may have a conflict in selecting the
Symmetry ETF within a particular model because it has an additional incentive to decrease
the Model Portfolio's allocation to third-party ETFs in order to increase the investment

management fees it receives.

Symmetry reserves the right to change its fee schedule at its discretion by written
notification to the client. Should Symmetry’s fee increase, Symmetry must obtain written
consent from the client.

A portion of Symmetry’s fee, or an additional fee, as disclosed in the client’s Symmetry
Investment Advisory Agreement (or exhibit or schedule thereto), is deducted from the client
account and paid to the BD/RIA associated with the respective client. Should the fee be a
solicitation fee, the fee is specifically disclosed on the promotor’s disclosure statement.
The promotor’s disclosure statement is part of Symmetry’s investment advisory agreement.
For additional information about promotor arrangements, please see item 14 of this
brochure.

The additional promoter fee will vary but could be a maximum of 2.00%.

The aforementioned fee schedule applies to Outside Qualified Plans not participating in the
Symmetry Retirement Program, as described elsewhere in this brochure.

In certain circumstances, such as but not limited to, the distribution channel through which
the client is accessing Symmetry, the firm may charge more or less than their standard
schedule. As in all situations, the fee schedule is disclosed to the client.

Each Symmetry client will generally incur additional charges or expenses in connection
with the opening, maintenance and closing of his or her account(s) at an approved third-
party custodian, including, but not limited to brokerage commissions, transaction charges,
wire- related fees, qualified plan fees, and account closing fees.

Investments into funds, affiliated and unaffiliated alike, are subject to their internal expense
ratio. Such fees are separate and apart from Symmetry’s fees. Additional information
regarding fund fees is contained in such fund’s prospectus. A Plan utilizing Symmetry will
also generally pay fees to other service providers independent of Symmetry for such
services as recordkeeping, third- party administration, and access to internet-based
account enrollment and management.

The Direct Client

The direct client is charged Symmetry’s fee. A portion of Symmetry’s fee, or an additional
fee, is deducted from the client account and paid to the firm’s investment adviser
representative servicing the account. The direct client is also charged a custodian fee and
may incur transaction costs such as, but not limited to, wire fees, commissions and
termination fees. In addition, the direct client also pays fees and expenses related to the
client’s investments in the comingled vehicles. A description of these fees and expenses
can be found in each fund’s prospectus.

Symmetry’s standard tiered fee schedule, which may be negotiable in certain
circumstances, is set forth below. Depending on the nature and scope of services
...

ITEM 7: TYPES OF CLIENTS

A. Types of Clients

Symmetry provides services to individuals, trusts, charitable organizations, pension and
profit-sharing plans, corporations, and state and government entities, and Symmetry
Panoramic Funds.

B. Conditions for Managing Accounts

Clients who are interested in market timing cannot open an account at Symmetry.

On occasion, Symmetry may permit clients to maintain certain “non-discretionary” assets in
their advisory accounts.

All portfolios may not be available through all distribution channels.

Minimum Account Size

Although Symmetry has the authority to accept a lesser amount, the minimum account size
varies by strategy and generally ranges from $5,000 to $1,000,000. The firm may waive
these minimums at its discretion. Clients may make cash additions to their account(s) at
any time and may withdraw assets from their account(s) on written notice to the Firm.

For all amounts mentioned in this section, Symmetry may amend if administratively
feasible and at its discretion.

Model Portfolios

Client investments may not match exactly the target allocations for the applicable model
portfolio due to a variety of implementation and market movement factors, including but not
limited to: the custodian or trading platform’s own trading algorithm, or any change in price
from the time the positions are calculated to the time they are traded. In some cases, with
certain custodians, positions with small allocations may be eliminated altogether.
Symmetry may determine not to implement changes made to the applicable model
portfolio due to client-specific factors, such as, but not limited to, the client’s desire to avoid
realized capital gains or otherwise.

The holdings comprising the model portfolios and the allocations to those holdings have
changed over time and may change in the future.

The firm typically maintains a cash position in each portfolio. The cash positions may be
invested in a money market fund which will vary depending on the custodian.

For all portfolios, changes to holdings which comprise the portfolios may have tax
consequences. If the client sells assets in a taxable account, the client may have to pay tax
on any gain. While Symmetry seeks to mitigate tax exposure when possible, it is likely that
investors will incur a taxable event while being invested in the portfolios.

Operational Requests

Please note that Symmetry will use best efforts to invest deposits and process model
change requests within five (5) business days of receipt. Distributions from accounts may
take up to ten (10) business days from receipt of request due to settlement dates,
administrative duties and other involved institutions’ various timelines. Please note that
distributions or transfers related to the closing of an account may take up to thirty (30)
business days.

Please note, upon termination of an account, the custodian and/or firm to which the client
is transferring their account may not be able to hold the funds in which the client is
currently invested.

On occasion a client who has retained the services of Symmetry Partners, will transfer
their current holdings to the receiving custodian, (one of the custodians Symmetry is
utilizing), in kind. When this occurs, Symmetry will liquidate all securities received in kind
as soon as administratively feasible, provided there is a market (U.S.) for the security.

A client who does not want non-model securities liquidated must request so in writing. This
request is subject to the approval of Symmetry and/or custodian. In some cases, certain
types of securities cannot be held by the custodian. In such cases, the client must request
and execute transfer documentation to have the in-kind securities returned to the
originating custodian. If the transfer documentation is not received by the custodian within
30 days of receiving the in-kind securities, then Symmetry Partners will liquidate those
securities.

Trade Error Process

Symmetry’s policy and process is to reconcile all trading activity. Symmetry seeks to
identify and resolve trade errors within a reasonable timeframe; document each trade error
with appropriate supervisory approval; and maintain a trade error file. Symmetry does not
engage in any soft dollar arrangements to correct trades and does not correct trades by
selling to or purchasing securities from other clients’ accounts. In the event Symmetry
makes an error that has a financial impact on a client’s account, Symmetry will generally
return the client’s account to the position it would have held had no error occurred.
Symmetry will evaluate each situation independently, and as such, in certain situations
may use other methods to make the affected clients whole. A corrective action may result
in financial or other restitution to the client’s account, or inadvertent gains being reversed
out of the account. Any corrective action may result in a corresponding loss to the party at
fault (Symmetry, custodian, or advisor). Other measures to correct an error may be
facilitated through a fee credit or a deposit to a client’s account, which may result in a
taxable gain. Symmetry’s corrective action to a client’s account is expected to be limited to
direct monetary losses and will not include any amounts that Symmetry deems to be
speculative or uncertain. Symmetry does not derive any economic benefit from correcting a
trade error. The trade policies and procedures of the custodian may also be a factor in the
correction of a trade error.