Thoroughbred Financial Services LLC

Item 5).

           For its Thoroughbred, Cambridge and BTS programs, TFS recommends itself as broker-dealer. At times, TFS
           will provide services to assist a client in monitoring and evaluating the performance of a subadvisor
           recommended by TFS and selected by the client. In some of these situations, TFS will recommend itself as
           the broker-dealer to execute trades for the account. If the client uses TFS as the broker-dealer, the client
           may pay rates that are not as favorable as those available through other brokerage firms. This could cost
           the client more money. In all these situations, TFS recommends itself because of:
                • its reasonable commission schedule, transaction costs and custodial costs
                • the ease of execution for its clients
                • the quality of the services provided to the client

          TFS has a financial incentive to recommend itself as broker where possible. Directed brokerage
          arrangements are generally not permitted.

          In certain limited instances, TFS will manage a qualified retirement plan or charitable giving account
          custodied at either Charles Schwab and Company (“Schwab”) or Fidelity Custody (“Fidelity”) where the plan
          trustee specifically mandates all participant assets are held in custody with those firms. In these cases,
          those firms are acting as executing broker-dealer and custodian of client assets. Generally, neither Schwab
          nor Fidelity charges the client separately for custody services but is compensated by charging the client
          commissions or other fees on trades that it executes or that settle into the client account. [For some accounts
          they may charge the client a percentage of the dollar amount of assets in the account in lieu of commissions.
          The client will engage directly with Fidelity or Schwab to determine the appropriate charges. TFS is not
          involved with the discussion of this arrangement.]

12.B. Aggregation of Client Orders
          Generally, client portfolios are made up mostly of mutual funds and ETFs. At times, TFS makes
          recommendations on the purchase or sale of individual securities positions. In cases where a TFS
          representative is exercising discretionary authority to purchase or sell individual securities positions for
          multiple clients of the representative in the same day, TFS will aggregate the purchase or sale of the
          securities for the clients on a best effort basis.

          When TFS aggregates its orders for client accounts, TFS can assure each client will receive the same pricing.
          However, TFS does not normally purchase or sell individual securities in amounts large enough that
          aggregate orders would produce lower overall transaction costs.

          With regard to wrap accounts (see Appendix 1), outside money managers serve as subadvisor and have
          discretionary trading authority. When they make changes to the holdings of our clients’ wrap accounts,
          they will normally aggregate or block trade client orders to assure a fair price is obtained for all of the
          clients.

Item 7 Types of Clients

TFS generally provides investment advice to individuals, trusts, estates, charitable organizations, corporations,
partnerships, limited liability companies, pensions and profit-sharing plans. With regard to the Envestnet
Program, there is a $100,000 minimum account size.