Tingey Financial Group Inc

Fees and Compensation
TFG offers its management services for a fee based on assets under management. Fees are billed quarterly with no minimum
fee. Client fees for assets under management are assessed and paid at the beginning of each quarter. The quarterly
percentage fee (calculated as ¼ of the annual fee percentage) is applied against the fair market value of the account at the end
of the previous quarter. Fees are billed directly to the custodian unless the client has requested a separate invoice and payment
mechanism. Fees for management services may be charged intra-quarter when new assets enter the account. Conversely,
fees may not be reimbursed for assets that leave a portfolio during the quarter if it does not involve termination of services. Pre-
paid fees for portfolios that terminate TFG advisory services during the quarter (with at least 2 days’ written notice) will be
refunded pro rata by a returned check. Under circumstances unique to the client, investment management fees may be
negotiable, such as if the portfolio is part of a larger household of portfolios managed by the Adviser, or if the client has
requested that certain assets not be altered within the portfolio. Individual requests are reviewed on a case-by-case basis and
may be accepted or denied and must be agreeable to both parties. Any decision to use a negotiated fee rather than the
company standard fee must be affirmed in writing.
                        Annual Fee Percentage              Quarterly Fee Percentage
                   1.10% on the first $1,000,000           0.275% on the first $1,000,000
                   0.95% on the next $2,000,000            0.2375% on the next $2,000,000
                   0.85% on the next $2,000,000            0.2125% on the next $2,000,000
                   0.75% on the next $5,000,000            0.1875% on the next $5,000,000
                   0.50% on assets > $10,000,000           0.125% on assets > $10,000,000
The above blended fee schedule represents a conflict of interest for the Adviser in that the blended fee schedule may result in
higher fees for the Adviser than are collected by advisers who use a breakpoint schedule for the same or similar services.
Fees for general consulting services other than the basic investment management services described above, including expert
witness services, may be billed at a rate of $295.00 per hour. In such cases, the client’s project will be defined up front, and
payment will be by invoice and check unless the client requests and authorizes a direct payment from the client’s account.

Other than the fees stated above, TFG will not charge additional fees for its management services. The client may incur
brokerage or other transactional costs. None of the supervised people accept compensation for the sale of securities,
investment products, or as a placement agent for limited partnership interests. Additional information is provided under the
paragraph entitled “Brokerage.”

                                  Performance Based Fees and Side-by-Side Management

TFG does not charge fees based on performance nor does it participate in any wrap fee program. It also does not compensate
its employees by performance-based fees.

Types of Clients

TFG may provide investment advice to the following types of entities: Individuals and institutions, including Trusts, Foundations,
Charitable Organizations, Corporations, Partnerships, Unions, Pension and Profit-Sharing Plans, 401(k) and other qualified
retirement plans. The adviser has no formal conditions for opening or maintaining an account.

                                        Methods of Analysis and Investment Strategies
Tingey Financial Group offers investment advice to individuals and institutions based on the following disciplines in the equity
and fixed income capital markets. Specifically, TFG may offer advice on securities such as, but not limited to: stocks; warrants;
government, corporate or municipal debt or fixed income securities; mutual fund shares; exchange traded funds (ETFs); and
real estate investment trusts. Adviser does not use the categories of ETFs that carry higher risks as part of its portfolio
construction. These securities carry risks and uncertainties that can cause the loss of all or a portion of a client’s investment
portfolio. Stocks, warrants, mutual fund shares, ETFs and real estate investment trusts are subject to the general risks of the
strength of the economy, equity market fluctuations and risks inherent in the issuer of the security such as debt levels, market
positions, product acceptance in the marketplace, management expertise, etc. Government, corporate or municipal debt or
fixed income securities are subject to market swings brought on by interest rate movements as well as the financial strength and
credit rating of the individual issuer.

                                         Equity Investment Philosophy and Discipline:
Tingey Financial Group incorporates a fundamental, value-oriented investment philosophy and seeks to uncover the intrinsic
value of a security based on general market factors or those related directly to the security, such as revenues, earnings, cash
flows, dividend yields, balance sheet strength, liquidity, market position, management commitment to shareholders, etc. While
fundamental analysis is the basis for TFG’s research and decision-making, TFG may also use technical analysis, cyclical
analysis, and charting analysis to augment its fundamental efforts. Nevertheless, despite the commitment to fundamental

                                                                                      Version Date: 10 February 2025              3

analysis and other analytical tools, any investment in securities carries with it material risks and uncertainties that could cause
investors to lose all or a portion of their principal investment.

TFG seeks long-term growth opportunities in what it views as high-quality, undervalued assets that offer proven track records.
As such, TFG’s lower turnover investment philosophy lends itself to longer-time horizons that seek long-term, rather than short-
term, capital gains in growing markets. TFG seeks to invest in companies that are “value-priced” and offer opportunity over an
intermediate-term horizon; thus, time is an important factor to realize a company’s value.

Liquidity is a fundamental underpinning at TFG. Investments focus on stocks, bonds and other assets that are highly liquid and
can be converted quickly to cash and carry potential for growth of principal and interest. The cash portion of a client’s portfolio is
invested in highly liquid money market instruments, high quality commercial paper and U.S. Treasury bills or repurchase
agreements.

                                              Fixed Income Philosophy and Discipline
TFG adopts a buy-and-hold strategy for fixed income securities with an attempt to minimize risk by focusing on credit quality and
duration of portfolios. Liquidity is a major underpinning with an overall pursuit of investment grade credit quality, after-tax yield
and a value orientation relative to “normal” yield spread relationships and inflation expectations. Fixed income holdings are
generally held to maturity to keep transaction costs low and to allow the full yield to be achieved. With our dedication to
attractive credit quality, low turnover and penchant to avoid material duration risk, we attempt to reduce risk and enhance total
return in fixed income portfolios. Similar fixed income strategies are implemented throughout the breadth of investment
objectives and can be seen in balanced and fixed income portfolios alike. Investment decisions involve fundamental analysis of
the issuer along with analysis of general market risk, interest rate risk, re-investment risk, ill-liquidity risk and the risk of capital
loss. Third-party rating agency reports are resources for our fundamental analysis of fixed income.

Most portfolios will have a portion of the asset allocation in fixed income securities, which will generally be invested in liquid,
investment-grade individual securities. Just as in equity strategy, fixed income strategy involves diversification of risk, especially
in non-US Gov’t issues. The securities may include any or all of the following: US Treasury securities, US Government Agency
securities, corporate and municipal bonds, mortgage-backed securities or preferred stock. Cash is invested in highly liquid
money market funds, including FDIC sweep vehicles, high quality commercial paper and US Treasury Bills or repurchase
agreements. With fixed income security issues that are held for multiple years, the rating may drop below investment-grade
standards. At that point, TFG may decide to liquidate the position or to hold the position depending on the fundamental
variables in place. From time to time, TFG may purchase non-investment-grade bonds if it senses strong fundamental value. In
each situation, TFG would purchase these bonds after analysis and the conclusion that such bonds were likely to offer positive
...