Trustwell Financial Advisors LLC

Fees & Compensation (item 5)
   Fees for Financial Planning

   The amount we charge to perform financial analysis and develop a financial plan depends
   on the size, complexity, and nature of your personal and financial situation and the
   amount of effort required to gather necessary information, analyze your options, and
   develop recommendations.

   Clients pay for TrustWell’s financial planning work in one of two ways:

        •   As a fixed project fee (ranging from $600.00 to $10,000.00)
        •   As an hourly rate ($250.00 per hour)

   In every case, our fee is fully disclosed and the terms of the engagement are agreed to and
   documented in a written and signed financial planning agreement between the client and
   TrustWell before any work begins. TrustWell normally requires a deposit against the
   agreed fee, with the balance due upon completion and our presentation of analysis and
   recommendations. We maintain, however, the option to require full pre-payment for
   some engagements, or to require phased payments for especially large or long
   engagements. Financial planning engagements are generally finished within 90 days of
   the project’s start, provided we receive all necessary financial information without
   unusual delay.

   Your implementation of the plan may require additional time to complete and additional
   costs to you. This is especially true when the action steps require use of outside
   professionals such as estate attorneys, CPAs, etc.

   Termination of Financial Planning Services

   You may terminate your Financial Planning Agreement with TrustWell at any time
   before the completion of our work by giving written notice to us.

   Money Back Guarantee for Financial Planning

   If, at the time we present our analysis report and planning recommendations, you feel that
   our work is insufficient to your needs, less than you expected, and/or otherwise not worth
   the fee you agreed to pay, then no fee is due. If you have paid a deposit against the fee,
   we will refund that deposit to you.

   Fees for Asset Management

   TrustWell charges for asset management services on an asset-based fee arrangement.
   Clients for whom TrustWell manages their account(s) pay a quarterly fee based on the

Form ADV: Part 2A                                                         TrustWell Financial Advisors, LLC

                                                                            Disclosure Brochure

   average daily balance6 in the account(s) during the service period. The fee is calculated
   using the average daily balance of all assets maintained in the account(s) during each day
   of the calendar quarter (90 days) then multiplying that average daily balance by one-
   fourth the corresponding annual percentage rate (for example, 1.00%  4 = 0.25%) to
   determine our management fee for the quarter. Fees for asset management are calculated
   and collected from client accounts at the end of each calendar quarter.

   We retain the right to negotiate the management fee on a client-by-client basis.
   Generally, fee rate reductions occur as assets in your portfolio increase. The table below
   shows our management fees based on three tiers:
                                                            Quarterly      Annual
              Account Balance
                                                            Fee Rate       Equivalent
              Up to $1,000,000                              0.25%          1.00%
              $1,000,001 to $5,000,000                      0.20%          0.80%
              Over $5,000,000                               0.15%          0.60%

   We generally require a minimum initial investment of $100,000 to open an account, but
   we reserve the right to waive this minimum.

   The portfolio management fee rate will be fully disclosed to you in a written investment
   advisory agreement that both you and TrustWell sign before we begin any asset
   management services. Each asset management client receives account statements from
   the custodian (Schwab) which shows our asset management fee that was automatically
   deducted from your account.

   Asset management clients also pay two other fees:

         •   Ongoing expenses paid to the mutual funds, ETFs, etc. that TrustWell buys on
             your behalf
         •   Transaction fees paid to the third party custodian (Schwab)

   TrustWell does not receive a share of either of these additional fees and we attempt to
   keep them as low as possible.

       When choosing average daily balance, our system first determines the maximum
       number of days from which to retrieve prices and then accumulates the values for each
       asset on each day of the period. This accumulation is then divided by either the total
       number of days the asset balance was not zero or the total number of days in the period.
       If an asset was held less than the whole period, its accumulated value is prorated.
       Finally, the averages for each asset are summed to obtain the average daily balance for
       the portfolio.
Form ADV: Part 2A                                                        TrustWell Financial Advisors, LLC

                                                                             Disclosure Brochure

   Billing for Asset Management

   Your asset management account will be billed quarterly at the end of the service period
   based on the average daily balance of the assets in your account during the service period.
   For the first billing quarter, if the management account was not opened at the beginning
   of the quarter, the fee will be determined based upon a pro-rated calculation of the
   average daily balance of your assets managed for the calendar quarter.

   Advisory fees will be taken first from free credit balances or from any money market
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Types of Clients (item 7)
   The types of clients we offer advisory services to are described under “Who We Are” on
   page 5. Our minimum account size for portfolio management is shown on page 12.

   Methods of Investment Analysis, Strategies, & Risk of Loss (item
   8)
   Our portfolio management approach seeks to incorporate your financial needs and
   investment objectives, time horizon, and risk / loss tolerance to yield an effective
   investment strategy. Absent special circumstances, we seek real diversification in the
   portfolios we manage – not just within a particular asset class, but across multiple asset
   classes.

   Using your input, we build a portfolio for you that is tailored to these unique investment
   parameters. Through your account at Schwab, we have access to a wide range of
   investments. In building your portfolio, and managing it on an ongoing basis, we may
   use many different types of securities.

   For equity (stock) portions of a portfolio, we normally use mutual funds and exchange
   traded funds (ETFs), but we may also use individual stocks. Mutual funds and exchange
   traded funds carry additional management fees that the client must bear, but we believe
   the additional diversification they provide are worth their cost. Some asset management
   clients ask to have specific stocks included in their portfolios. We will add them (or keep

Form ADV: Part 2A                                                        TrustWell Financial Advisors, LLC

                                                                              Disclosure Brochure

   them) on your specific direction, but we will not include those individual stocks in our
   ongoing monitoring and we will not attempt to trade them in generating a profit.

   For bond (debt, or fixed income) portions of a portfolio, we normally use bond mutual
   funds, bond fund ETFs, individual bonds, or some combination of the three.

   For other portions of a portfolio, like precious metals, commodities, natural resources,
   CDs, real estate, etc., we may use mutual funds, ETFs, individual CDs, hedge funds,
   closed end funds, separately managed accounts, or other types of investments.

   Methods of Securities Analysis

   In analyzing stocks, bonds, mutual funds, and ETFs, we may use fundamental, technical,
   and/or cyclical approaches to gathering information and to guide us in our allocation and
   management decisions. Each of these methods has flaws.

   Fundamental analysis considers economic conditions, earnings, cash flow, book value
   projections, industry outlook, politics (as it relates to investments), historical data, price-
   earnings ratios, dividends, general level of interest rates, company management, debt
   ratios and tax benefits. Fundamental analysis is most commonly associated with
   selecting individual stocks. In nearly all cases, we use mutual funds and ETFs instead of
   individual stocks, and we do not perform fundamental analysis on any of the individual
   securities held by the funds or ETFs we purchase on your behalf. Our fundamental
   analysis work is of the larger economy, and of particular segments of the investment
   universe and this work may influence our investment decisions.

   Technical analysis considers current and historical pricing information for various types
   of securities in seeking to identify trends in the broader domestic and foreign equity and
   fixed income markets, and in the underlying assets themselves. Technical analysis may
   involve the use of various technical indicators, such as moving averages and trend-lines,
   to help make predictions about short and long term movements in asset prices.

   Cyclical analysis considers the relative movement of various market indicators in an
   attempt to anticipate rising or falling demand for different asset classes. These indicators
   may help us make adjustments to the relative weighting of assets within your portfolio
   and buy or sell particular assets at opportune times.

   Investment Strategies

   We are not bound to any specific investment strategy or ideology for the management of
   your investment portfolio except for our commitment to attempt to match the nature of
   your portfolio to your tolerance for volatility and to frequently review the asset allocation
   within your account. Investment account balances experience ups and downs that cannot
   be predicted or avoided. In no case is the performance of a particular investment, or an
   investment portfolio, guaranteed.

Form ADV: Part 2A                                                          TrustWell Financial Advisors, LLC

                                                                              Disclosure Brochure

   Some asset management clients prefer to avoid, as much as possible, holding companies
   within their portfolios that profit from, or actively support, certain business activities or
   products or are in locations those clients find offensive. This “screened” investing
   strategy is optional, and for those clients that choose it, it’s available in multiple flavors.
   Some clients prefer “BRI” (Biblically responsible investing) screens. Others prefer
   “ESG” (environmental, social, and governance) screens, and still others prefer “SRI”
   (socially responsible investing) screens. Many of our clients want nothing to do with
   non-financial considerations when building a portfolio. We do not presume to know any
   client’s wishes on these options, so we ask. When a client requests that we limit their
   portfolio to investments that are in keeping with their personal values, we will attempt to
   apply positive and/or negative screens as part of our investment selection process.
   Screened funds often have higher expenses and are often less diversified than unscreened
   funds, and they may underperform their unscreened peers. We encourage clients to share
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