TD Ameritrade Investment Management LLC

Fees and Compensation
		 i. Financial Planning
Clients will be notified in the event that TDAIM charges fees for financial planning, as they are not currently being charged.

		 ii. Selective Portfolios Using Mutual Fund Investments
			                           a. Core Mutual Fund Portfolios and Managed Risk Portfolio Fee Schedule (effective April 1, 2022)

                                    Account Value                                        Annual Advisory Fee*

                                    First $0 -$100K                                      0.90%

                                    Next $100k - $250k (or portion thereof)              0.70%

                                    Next $250k - $500k (or portion thereof)              0.50%

                                    Next $500k - $1M (or portion thereof)                0.30%

                                    Additional assets above $1M +                        0.20%

			                           b. Supplemental Income Portfolios Fee Schedule (effective April 1, 2022)

                                    Account Value                                        Annual Advisory Fee*

                                    First $0 - $100k                                     0.75%

                                    Next $100K -$250K (or portion thereof)               0.60%

                                    Next $250k - $500k (or portion thereof)              0.45%

                                    Next $500k - $1M (or portion thereof)                0.30%

                                    Additional assets above $1M +                        0.20%

                                 * In connection with this fee, it is TD Ameritrade’s policy to not charge commissions for all eligible transactions in
                                   TD Ameritrade Investing Accounts. The minimum initial investment is generally $25,000 and $100,000 for certain
                                   business accounts. The maximum initial investment will vary depending on the model and suitability considerations.
Please note that TDAIM’s advisory fees may be waived, in whole or in part, at our sole discretion, including in connection with promotional efforts or
special pricing arrangements. In addition, the fee may be waived, in whole or in part, for employees and certain former employees of TD Ameritrade
and its affiliates. We also reserve the right to negotiate pricing in individual circumstances for clients with large accounts or multiple accounts, not
assess the minimum annual fee in certain circumstances, provide offers to new and prospective clients, and may grandfather the annual advisory fee
of pre-existing advisory relationships. We do not bill advisory fees on accounts with an account value of $1,000 or less. All pricing is subject to change
on reasonable notice.
The applicable TDAIM fee will be assessed at the beginning of each quarter, in advance for that quarter. Clients will implement our advice through
a TD Ameritrade Investing Account and the fee will be deducted from the assets in the related introducing account held at the affiliated clearing
brokerage firm, TDAC. If the client opens their related TD Ameritrade account during a quarter, we will collect a prorated fee for the balance of the
quarter upon account funding.
Advisory fees are not charged on assets that are not directly under our management. This means that fees are not charged on (i) cash outside of the
portfolio strategy (for example, client-initiated transactions to raise cash for future withdrawal) or (ii) on incompatible securities that are temporarily
held in the related TD Ameritrade account. Advisory fees will be charged for all other compatible assets, including cash held within the portfolio
strategy.
If the client closes their related TD Ameritrade account during a quarter, TDAIM will refund to the client the unearned portion of the previously
collected fee, which will be calculated on a prorated basis by days. The Core Mutual Fund, Supplemental Income Portfolios, and Managed Risk
Portfolio may use mutual funds or share classes that may not be available to you as a retail investor. If you terminate your advisory relationship with
TDAIM, we reserve the right to redeem any and all shares of such funds and you may incur a gain or loss from the liquidation. In lieu of liquidation, if
available, we reserve the right to convert the shares into a share class for which you are eligible and you will be subject to the terms and conditions
including expenses per the mutual fund prospectus and there may be tax consequences.
The above pricing is in the context of clients who deal directly with TDAIM and TD Ameritrade. We reserve the right to provide our services to other
types of clients (such as participants in 401(k) plans) and in other contexts (such as portfolio consulting). We also reserve the right to vary our fee
structure for such other types of clients and in such other contexts, as well as for TD Ameritrade employees.
If the market value of a client’s account falls below the minimum for his or her strategy due to him or her withdrawing assets from the account, or
otherwise falls significantly below the specified minimum to a level where TDAIM believes the account can no longer be managed in accordance with
its investment strategy, TDAIM may require the client to deposit additional money to bring the account up to the required minimum, and we reserve the
right to discontinue the advisory relationship and transfer the securities into a like-titled brokerage account with TD Ameritrade.

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Mutual fund companies utilized by the Selective Portfolios service reserve the right to charge fund-imposed, short-term redemption fees as detailed
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Types of Clients
TDAIM generally provides financial planning and asset allocation services to individuals and trusts, but may provide such services to institutions, as
well. These services are provided through the Internet or software applications to a national clientele. The financial planning services are incidental to
the asset allocation services.
The TDAIM asset allocation services are made available to brokerage clients of TD Ameritrade. The minimum initial investment for the Selective
Portfolios services required for a TD Ameritrade Investing Account is generally $25,000 (minimum investment amount for corporate/business accounts
is $100,000). The minimum initial investment for the Essential Portfolios service for a TD Ameritrade Investing Account is: 1) $500 on the condition
that you set up automatic recurring deposits through your TD Ameritrade Investing Account. Recurring deposits are available by electronic bank
transfers (ACH). If recurring deposits cease before reaching a $5,000 balance in your TD Ameritrade Investing Account, we will require you to re-
authorize recurring deposits or deposit additional money to bring your account up to $5,000. If these conditions are not met, we reserve the right to
discontinue our advisory relationship with you and transfer the securities into a like-titled account with TD Ameritrade; or 2) $5,000; or 3) $100,000 for
corporate/business accounts The minimum initial investment for the Personalized Portfolios service required for a TD Ameritrade Investing Account
is $250,000 for a portfolio consisting of one or more individual accounts, each having at least a $50,000 minimum. If the market value of a client’s

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account falls below the minimum for his or her strategy due to him or her withdrawing assets from the account, or otherwise falls significantly below
the specified minimum to a level where TDAIM believes the account can no longer be managed in accordance with its investment strategy: 1) the
client’s asset allocation of his or her portfolio may vary from the target asset allocation due to the lack of funds, 2) TDAIM may require the client
to deposit additional money to bring the account up to the required minimum, and we reserve the right to discontinue the advisory relationship and
transfer the securities into a like-titled brokerage account with TD Ameritrade. If you set up automatic recurring deposits, it is possible that smaller
deposits may not always be invested as investing and your portfolio rebalancing occur when certain parameters are triggered which is designed to
keep your portfolio close to its target allocation. Furthermore, the terms and conditions applicable to a TD Ameritrade Investing Account will apply to
any brokerage activities in such an account.

Methods of Analysis, Investment Strategies, and Risk of Loss
		 i. Selective Portfolios Using Mutual Fund Investments and the Managed Risk Portfolio
TDAIM has retained CSIM as an investment consultant to provide asset allocation and fund selection services for the portfolios.The Core Mutual
Fund Portfolios are diversified asset allocation portfolios.
The Supplemental Income Portfolios are diversified asset allocation portfolios generally for more conservative investors who may want supplemental
income for retirement or other purposes or as a complement to other investment strategies with a secondary goal of growth. Due to the conservative
nature of the portfolios, TDAIM has created only two models: Conservative and Moderate. The Managed Risk Portfolio is designed to use an absolute
return strategy to limit volatility and provide protection against a decline in the equity markets. TDAIM will establish the asset allocations. The asset
allocation methodology is based on two factors: 1) an estimate of risk/return parameters relying on historic, current, and forecasted data; and 2) the
use of a tactical asset allocation tool based on modern portfolio theory.
The TDAIM fund universe includes the mutual funds available on the TD Ameritrade platform. The funds are carefully screened and analyzed by
TDAIM using a set of qualitative and quantitative factors. The factors include but are not limited to risk-adjusted performance, variance of returns, tax
efficiency, expenses (including as to different expense levels associated with different mutual fund share classes), style consistency, and style purity
as described above in Advisory Business iv. Mutual Fund Recommendations.
The selected funds are generally no-load or load-waived mutual funds on the TD Ameritrade platform. The classes of these funds may include retail,
institutional, or other share classes, depending on TD Ameritrade’s agreement with a particular mutual fund or its service providers. We will attempt
to obtain waivers of short-term redemption fees and purchase minimums where possible, as well as to access to lower expense share classes, where
available. We will attempt to ensure that the lowest expense share class available to clients on the TD Ameritrade platform is being selected. In some
cases, however, the less expensive share class may not be available to TDAIM clients.
Information used in making the goal planning and TDAIM asset allocation recommendations is based upon industry accepted methods and criteria
for evaluating a client’s investment goals, based upon information provided by the client relating solely to the assets each client chooses to invest in
accordance with a financial plan or a TDAIM asset allocation model.
The principal TDAIM investment strategy is the long-term purchase of funds (investment time horizon of more than one year). However, depending
on the circumstances, and as a result of factors such as client liquidity needs, rebalancing, profile changes, and allocation model adjustments, not all
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