Trident Advisors Inc

Fees and Compensation - Item 5

 All investment advisory services are provided by Trident pursuant to a written investment advisory agreement
 between Trident and each client. The investment advisory agreement for each client sets forth the fees to be
 charged to client for the services received. Trident generally charges its advisory clients an annual investment
 management fee based upon a percentage of the market value of the assets being managed by Trident. In limited
 circumstances, a flat fee may be negotiated for advisory services. In general, the investment management fee
 charged by Trident varies depending upon the market value of the assets under management and the specific
 type of investment management services to be rendered. Fees are negotiable with each individual client. Trident’s
 fees are not based on the capital gains of any client account. Trident reserves the right to negotiate and/or change
 its fee schedules for new or existing clients, while continuing to charge some or all of its existing clients on the
 basis of fees and agreements in force prior to the change.

 Generally, we charge an investment management fee of up to 2.25% of a client’s assets under management.
 Other compensation arrangements may be negotiated with clients on a case-by-case basis. Such arrangements
 will be clearly listed in the advisory agreement signed by the firm and the client.

 In the investment advisory agreement for each client, and the agreement with the client’s custodian, a client can
 authorize Trident and the client’s custodian to deduct investment management fees directly from such client’s

Trident Advisors, Inc.
Form ADV Part 2A

 account for advisory services provided. Such fees are prorated, if applicable, and paid quarterly or monthly in
 arrears, based upon the market value of the assets on the last day of the previous quarter or month, as applicable.

 Generally, the custodian holding the client’s account will deduct Trident’s fees and any other custodial fees
 directly from a designated account to facilitate billing provided the client has given written authorization. The
 qualified custodian will send an account statement at least quarterly. This statement will detail all account activity.
 Fees may be deducted from a single designated client account to facilitate billing. In limited circumstances, at our
 sole discretion, we may agree to invoice you directly for our advisory fee or we may negotiate other fee payment
 arrangements. The investment advisory fees charged by Trident, as discussed above, do not include any custodian
 fees that a client may have to pay to a custodian.

 In addition, certain classes of mutual fund shares (including ETFs) held in a client’s account will also be subject to
 sales charges, Rule 12b-1 fees, short-term redemption fees and other mutual fund expenses. Fees and expenses
 of mutual funds in which a client may invest are fully disclosed in the mutual fund’s prospectus. The fees charged
 by Trident are separate and distinct from any fees and expenses charged by mutual funds. Mutual funds generally
 pay advisory fees to their investment advisers and such fees would be paid indirectly by all mutual fund
 shareholders. If a client has mutual funds in its account, the client is effectively paying both Trident and the mutual
 fund investment adviser for the management of the assets in the client’s portfolio.

 Billing on Cash Positions: Trident treats cash and cash equivalents as an asset class. Accordingly, unless otherwise
 agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of
 assets under management for purposes of calculating the firm’s advisory fee. At any specific point in time,
 depending upon perceived or anticipated market conditions/events (there being no guarantee that such
 anticipated market conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for
 defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts
 could miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could
 exceed the interest paid by the client’s cash or cash equivalent positions.

 Periods of Portfolio Inactivity: The firm has a fiduciary duty to provide services consistent with the client’s best
 interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to
 determine if any changes are necessary based upon various factors, including but not limited to investment
 performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial
 circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may
 be extended periods of time when the firm determines that changes to a client’s portfolio are neither necessary
 nor prudent. Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee will
 continue to apply during these periods, and there can be no assurance that investment decisions made by the
 firm will be profitable or equal any specific performance level(s).

 Unless the client directs otherwise, Trident primarily recommends that the broker-dealer for all investment
 management accounts be maintained with Cresap, Inc. (“Cresap”) and that the account be maintained at and
 cleared through Wells Fargo Clearing Services/First Clearing Corp., a subsidiary of Wells Fargo & Company (“FCC”).
 Prior to engaging Trident to provide investment management services, the client will be required to enter into a
 separate agreement with Cresap/FCC, or other designated broker-dealer/custodian of the client’s investments,
 setting forth the services to be provided and applicable fees and/or charges.

Trident Advisors, Inc.
Form ADV Part 2A
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Types of Clients - Item 7

 Trident provides investment advice primarily to individual investors, corporate clients, trusts and non- profit
 organizations.

 Trident generally requires an account minimum of $50,000 for investment management services. However,
 Trident, in its sole discretion, may charge a lesser management fee or waive its minimum account size based upon
 certain criteria (e.g., anticipated future earning capacity, anticipated future additional assets, dollar amount of
 assets to be managed, related accounts, account composition, pre- existing clients, etc.).

                         Methods of Analysis, Investment Strategies and Risk of Loss - Item 8

 Trident’s overall investment philosophy focuses on the rewards of long-term investing. For each client,

 Trident’s approach emphasizes style allocation as the first and most important step in the construction of a client
 portfolio. In determining style allocation, Trident focuses on the client’s risk tolerance, income needs and time
 horizon. Once allocation percentages are established, the equity component of the client’s portfolio is
 constructed based upon a careful evaluation of the parameters suggested by client risk tolerance and time
 horizon. Trident then invests the client’s assets in securities or funds.

 In connection with this strategy, Trident also has developed a “style allocation matrix” that allows clients to
 participate in a wide array of disciplines, allowing for greater diversification and more consistent performance
 while reducing the risks created by concentrating in one particular style. These style allocation matrices range
 from conservative strategies to long-term growth strategies.

 In determining the securities or funds to which a client’s assets should be allocated, Trident may use the following
 sources of information in its research, among others:
      •   financial newspapers and magazines;
      •   research materials prepared by others;
      •   corporate rating services;
      •   annual reports, prospectuses and other filings with the SEC; and
      •   company press releases.

 In selecting specific securities for a client’s portfolio in accordance with its asset allocation strategy, Trident may
 use charting, fundamental and/or technical methods of security analyses to determine which securities are the

Trident Advisors, Inc.
Form ADV Part 2A

 most attractive investments. Trident invests the assets of its clients’ accounts in any of the following types of
 investments pursuant to the client’s investment objectives and policies:
     •    equity securities of U.S. or foreign issuers (including exchange-listed and over-the-counter (OTC)
          common stock, preferred stock, convertible securities and warrants, among others);
     •    corporate or government debt securities of U.S. or foreign issuers or countries (including U.S.
          government securities, commercial paper, certificates of deposit and municipal securities, among
          others);
     •    investment company securities (including mutual funds, ETFs and variable annuities);
     •    options contracts on securities; and
     •    any other investments that Trident feels would be appropriate for a particular client under the individual
          facts and circumstances.

 Equity Investing
 Trident’s equity investment philosophy stresses growth investments at a fair price. Trident focuses on large
 companies with leadership positions within their respective industry groups. The investment process starts with
 a "top-down" approach, evaluating overall economic factors to determine sector allocation before selecting what
 Trident believes to be the most promising investments within each industry group.

 Fixed Income Investing
 Fixed income securities are evaluated for purchase in a client’s portfolio based upon the credit rating, stability of
 the issuer and the level of income needed by the client. In all cases, careful consideration is given to the client’s
 stated risk tolerance.

 Investment Risks
 As with all investments, you can lose money by investing the securities markets. Investing in securities involves
 the risk of loss of some or all of your investment. You should be prepared to bear the loss of your investment
 before investing.

 The following are additional risks applicable to investments according to Trident’s investment strategies:

 Asset Allocation Risk – A client’s ability to achieve its investment goal depends upon Trident’s skill in determining
 the appropriate asset allocation mix for the client and in selecting securities and funds in which to allocate the
 client’s assets. There is the possibility that Trident’s evaluations and assumptions regarding asset allocation will
 not successfully achieve high long-term total return in view of actual market trends.

 Stock Market Risk - The market value of securities may go up and down, sometimes rapidly or unpredictably. A
 security’s market value may fall due to market activity or due to supply and demand.

 Smaller and Mid-Sized Companies Risk - Securities issued by smaller and midsize companies may be more volatile
 in price than those of larger companies and may involve additional risks, including that such companies may be
 more sensitive to economic conditions, may have less certain growth prospects, may lack depth of management
 and funds for growth and development, and may have limited or less developed product lines.

 Management Risk - Trident applies investment techniques and risk analyses in making investment decisions, but
 there can be no guarantee that these decisions will produce the desired results.

Trident Advisors, Inc.
Form ADV Part 2A

 Interest Rate Risk – Interest rate changes can be sudden and unpredictable. When interest rates rise, debt
 security prices generally fall. The opposite is also true: debt security prices rise when interest rates fall. In general,
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