The Clifford Group LLC

Item 5 – Fees and Compensation

The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
agreement with the Advisor.

A. Fees for Advisory Services
Wealth management fees are paid quarterly, advance of each calendar quarter pursuant to the terms of the wealth
management agreement. Wealth management fees are based on the market value of assets under management at
the end of the prior calendar quarter. Wealth management fees range from 0.75% to 1.50% annually based on
several factors, including: the scope and complexity of the services to be provided; the level of assets to be managed;
and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements,
portfolio restrictions and other complexities may be charged a higher fee.

The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the
end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by
The Clifford Group will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the
Custodian’s valuation to ensure accurate billing.

The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other
related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor
shall not receive any portion of these commissions, fees, and costs.

B. Fee Billing
Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at
the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted
from the Client’s account[s] at the beginning of the] respective quarter. The amount due is calculated by applying the
quarterly rate (annual rate divided by 4]) to the total assets under management with The Clifford Group at the end of
the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction
of the wealth management fee. Clients are urged to also review the brokerage statement provided by the Custodian,
as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees
to be deducted by The Clifford Group to be paid directly from their account[s] held by the Custodian as part of the
wealth management agreement and separate account forms provided by the Custodian.

With respect to unaffiliated non-custodial partnership/private fund investments, which are not held at the Custodian,
the Client shall be required to complete applicable private placement and/or account opening documents to establish
these investments. The Advisor will debit its fee for providing investment advisory services with respect to these
relationships directly from an account designated by the Client held at the Custodian. For certain non- custodial
partnership/private fund investments, the Advisor may not receive quarter-end investment valuations prior to its fee
billing calculation. In such instances, the Advisor will use the most recent month-end or quarter-end valuation available
                                                   The Clifford Group LLC
                                    321 Commonwealth Road, Suite 103, Wayland, MA 01778
                                        Phone: (617) 600-2083 | https://thecliffordgrp.com

for the calculation of investment advisory fees.

C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf
of the Client’s account[s]. The Clifford Group includes securities transactions costs as part of its overall wealth
management fee through The Clifford Group Wrap Fee Program. Securities transaction fees for Client-directed
trades may be charged back to the Client. Please see Item 4.D. above as well as Appendix 1 – Wrap Fee Program
Brochure.

In addition, all fees paid to The Clifford Group for wealth management services are separate and distinct from the
expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are
described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for
the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a
possible distribution fee. A Client may be able to invest in these products directly, without the services of The
Clifford Group, but would not receive the services provided by The Clifford Group which are designed, among other
things, to assist the Client in determining which products or services are most appropriate for each Client’s financial
situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees
charged by The Clifford Group to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage
Practices for additional information.

D. Advance Payment of Fees and Termination
The Clifford Group may be compensated for its investment management services in advance of the quarter in which
services are rendered. Either party may terminate the wealth management agreement, at any time, by providing
advance written notice to the other party. The Client may also terminate the wealth management agreement within
five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client
will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and
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Item 7 – Types of Clients

The Clifford Group offers wealth management services to individuals, high net worth individuals, trusts, estates, and
businesses. The Clifford Group generally does not impose a minimum relationship size.