Torrey Growth & Income Advisors LLC

Fees and Compensation
Our fee for individual portfolio management services is based on a percentage of your assets we
manage and is set forth in the following blended tiered fee schedule:

                                                Equity                         Fixed-Income
 Assets Under Management                     Annual Fees                        Annual Fees
 Up to $1,000,000                              1.100%                             0.450%
 next $4,000,000                               0.850%                             0.400%
 next $5,000,000                               0.675%                             0.350%
 above $10,000,000                             0.500%                             0.275%

We aggregate related account balances of clients within the same household for purposes of
achieving the advisory fee breakpoints listed above. Our annual portfolio management fee is billed
and payable quarterly in advance based on the value of your account on the last business day of
the previous quarter. Fees will be debited from the account in accordance with the client
authorization in the Discretionary Investment Management Agreement. Our advisory fee is
negotiable depending on individual client circumstances. Existing clients may be under a different
fee schedule that was in existence at the time they joined our firm.
We will deduct our fee directly from your account through the qualified custodian holding your
funds and securities. The qualified custodian agrees to send you at least a quarterly statement
indicating all amounts dispersed from your account including the amount of the advisory fee paid
directly to our firm. We encourage you to reconcile the statements you receive from our firm and
the qualified custodian. If you find any inconsistent information within the statements, please call
our main office number located on the cover page of this brochure.

How Our Fees are Calculated
If you have an account balance of $1,250,000, you are billed 1.100% per year on the first
$1,000,000 and .850% per year on the remaining $250,000. Here are the calculations for a sample
account for a calendar quarter with 90 calendar days:

$1,000,000 X 1.100% /365 = $30.13 x 90 days = $2,711.70
$250,000 x 1% / 365 = $6.85 x 90 days = $616.50

The total Portfolio Management fee deducted for the quarter will be: $2,711.70 + $616.50 =
$3,328.20

Other Fees and Expenses
Clients may incur charges for other account services provided not directly related to the execution
and clearing of transactions, including, but not limited to, IRA custodial fees, safekeeping fees, wire
transfer fees, interest charges on margin loans, exchange fees, and fees for transfers of securities.

Additional Information about Fees and Expenses
As part of our investment advisory services to you, we sometimes invest in exchange-traded funds
and less frequently, mutual funds. The fees that you pay to our firm for investment advisory services
are separate and distinct from the fees and expenses charged by mutual funds or exchange traded

Torrey Growth & Income Advisors, LLC                                         Appendix 1 Wrap Fee Brochure

funds (described in each fund's prospectus) to their shareholders. These fees will generally include
a management fee and other fund expenses.

To fully understand the total cost you will incur, you should review all the fees charged by exchange-
traded funds, mutual funds, and our firm. Clients are cautioned that depending on the level of fees
charged by the executing broker-dealer and the amount of portfolio activity in the clients' account,
the fees charged for services provided under this Wrap Fee Program may exceed the total cost of
such services had they been provided separately. In addition, the Wrap Fee Program fee may be
higher or lower than that charged by other sponsors of comparable wrap fee programs.

Under no circumstances do we require or solicit payment of fees more than $1,200 in fees six or
more months in advance of services rendered.

ITEM 5 - ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS
Minimum Account Requirements

Grandfathering of Minimum Account Requirements and participation in the Wrap Fee
Program
Participation in the Wrap Fee Program is closed to new clients. Pre-existing advisory clients prior to
2018 were eligible to participate in the Wrap Fee Program. There were no minimum account
requirements.

Types of Clients
Torrey Growth & Income Advisors provides advisory services in the Torrey Growth & Income Wrap
Fee Program, where appropriate, to:

    •   Individuals
    •   High net worth individuals
    •   Trusts
    •   Estates
    •   Corporations
    •   Charitable Organizations
    •   Partnerships

ITEM 6 - PORTFOLIO MANAGER SELECTION AND EVALUATION
Selection and Review of Portfolio Managers
Portfolio management services for wrap program accounts are provided by TGIA’s investment
adviser representatives (“IARs”), who also manage portfolios for clients that are not in the wrap fee
program. TGIA assigns one or more IARs to each account based on factors such as the client’s
financial circumstances, investment objectives, risk tolerance, time horizon, tax considerations,
and the experience and availability of advisory personnel.

All portfolios are managed in accordance with TGIA’s investment philosophy, internal processes,
and applicable client guidelines. TGIA’s approach emphasizes diversified portfolios, risk
management, and alignment with each client’s stated objectives.

Torrey Growth & Income Advisors, LLC                                        Appendix 1 Wrap Fee Brochure

TGIA conducts ongoing supervisory review of portfolio management activities. This review includes
assessment of portfolio positioning, adherence to client mandates, trading practices, risk
exposures, and compliance with applicable policies and procedures. TGIA may reassign
responsibility for managing a client’s account among its IARs due to changes in client needs,
staffing considerations, or other organizational factors.

Standards Used to Evaluate Portfolio Manager Performance
Because TGIA serves as the sole portfolio manager for the wrap fee program, performance
evaluation focuses on the results achieved in client accounts relative to each client’s specific
objectives, asset allocation, risk tolerance, and investment guidelines.

Accounts generally differ significantly with respect to investment objectives, asset allocation,
restrictions, tax considerations, timing of contributions and withdrawals, and the length of time
assets have been managed by TGIA. As a result, performance comparisons among client accounts
may not be meaningful and portfolio management performance is not calculated on a uniform or
consistent basis across all accounts.

Performance is reviewed across multiple time horizons and in the context of prevailing market
conditions. However, performance is only one factor considered in evaluating portfolio
management. The scope of services provided to clients is also a factor in performance and may
include financial planning, fiduciary advice, and other advisory services in addition to portfolio
management.

Review of Performance Information
TGIA maintains internal records of account performance and regularly reviews results as part of its
supervisory processes. Performance data is derived primarily from custodial records at Charles
Schwab who also provides account statements directly to clients reflecting holdings, transactions,
and valuations.

Limitations of Performance Comparisons
Client account performance will vary based on numerous factors, including differences in account
size, timing of contributions and withdrawals, tax circumstances, client-imposed restrictions,
services provided, and asset allocation. Because of these differences, performance among client
accounts — including accounts in the wrap fee program — may vary substantially and may not be
directly comparable.

Past performance is not indicative of future results, and no assurance can be given that any
investment objectives will be achieved.

Related Persons Acting as Portfolio Managers
TGIA acts as the sole portfolio manager for all accounts in the wrap fee program. TGIA does not use
or recommend unaffiliated portfolio managers within the program. Accordingly, all portfolio
management services are provided by related persons serving as IARs of TGIA.

Because TGIA serves as both the sponsor of the wrap fee program and the portfolio manager, TGIA
receives the wrap fee as compensation for advisory services provided to participating clients.
Under the wrap fee arrangement, TGIA generally bears trading costs associated with transactions in
client accounts rather than passing those costs directly to clients. As a result, the wrap fee program

Torrey Growth & Income Advisors, LLC                                        Appendix 1 Wrap Fee Brochure

may be less economically advantageous to TGIA than other advisory arrangements in which clients
pay transaction costs separately. This structure may create an incentive for TGIA to recommend
that clients transition to a non-wrap advisory arrangement, where permitted.

TGIA addresses these conflicts through its fiduciary duty to clients, and its policies and procedures
designed to ensure that recommendations regarding advisory arrangements are based on each
client’s best interests, taking into account factors such as anticipated trading activity, services
provided, overall costs, and the client’s preferences. TGIA does not permit new clients to enter the
wrap fee program, which is maintained solely as a legacy program for existing participants.

Because TGIA is the only portfolio manager in the program, there are no external portfolio managers
for comparison. TGIA applies its internal supervisory and compliance processes to all portfolio
management activities, including those related to wrap fee program accounts. Portfolio
management activities are regularly reviewed by management for adherence to client objectives,
investment guidelines, risk parameters, and firm policies and procedures.

Supervised Persons Acting as Portfolio Managers
Portfolio management services under the wrap fee program are provided by supervised persons of
TGIA who are registered as investment adviser representatives. These individuals act on behalf of
TGIA and not as separate advisory firms.
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