Valley Forge Investment Consultants Inc

Item 5. Fees and Compensation

VFIC‘s compensation for its services is in the form of either asset-based fees or flat dollar fees. Asset based fees are
based on a percentage of assets under management, including cash. Our current fee schedule is set forth below
and applies to new clients onboarded on or after July 1, 2024. Current clients should consult their investment

advisory agreement for the schedule of fees appliable to their relationship. Under certain circumstances, VFIC will
consider an alternative fee arrangement.

Annual advisory fees for new clients onboarded on or after July 1, 2024

1.00% on the first $1,000,000
0.75% on the next $2,000,000
0.50% on the next $2,000,000
0.30% on the next $5,000,000
0.25% on assets above $10,000,000

*The VFIC Advisory fee pays only for the advisory services of VFIC. Fees for the custodian and any other fees are
payable separately, and do not accrue to VFIC or otherwise benefit VFIC.

Asset-based fees are calculated based on the total market value of the assets under management on the last
business day of each calendar quarter. VFIC relies upon the client’s custodian, or in some cases an aggregation
software, for client asset values. Certain clients are eligible for flat dollar fees that generally range from $7,500 to
$125,000 annually, based on account size, minimum fee requirements, length of client relationship and other factors,
and are not pro‐rated for additions or withdrawals.

All advisory fees are calculated and due either on a monthly or quarterly basis and are payable in advance or arrears.
Clients will be entitled to refunds of any paid but unearned fees upon termination. In any partial calendar quarter,
the fee will be pro‐rated based on the number of days in which we advised or managed the account during the
quarter. Fees and related terms of payment of such fees for all VFIC advisory services are governed by the terms of
the applicable client investment management agreement(s). Although the fee schedules set forth above represent
the fees generally in effect for new clients as of the date of this brochure, all clients will not be subject to the same
fee schedules. Terms applying to existing clients may vary pursuant to the fee schedules in effect at the inception
of the advisory relationships, while others may vary based on the client’s right to negotiate fees.

VFIC does not charge advisory fees for client assets that are invested in Valley Forge Funds nor are such assets
included in the aggregated asset valuations for purposes of applying VFIC’s fee schedule. However, as described in
this brochure, the sponsors of the Valley Forge Funds are affiliates of VFIC, and those affiliates and their related
persons receive certain fees and compensation from the Valley Forge Funds. In addition, the principal executive
officer of VFIC, Michael J. Maher, Jr. and other individuals associated with VFIC are also separately licensed as
registered representatives with M Holdings Securities, Inc. (MHS), an unaffiliated SEC registered broker‐dealer, from
which they receive commissions for the placement of certain variable insurance or annuity products and historically
received commissions on interests in the Valley Forge Funds. VFIC retains a portion of the commissions from MHS
to pay for VFIC overhead costs related to non‐investment advisory services such as monitoring, servicing, and
reporting for these investment types, and VFIC also retains the commissions from registered representatives who
have left the firm. Please see Item 12 of this brochure for important disclosures regarding our brokerage practices.
These commissions represent a conflict of interest because they give VFIC an incentive to recommend products for
which our affiliates receive commissions rather than based on clients’ needs.

Fees paid to VFIC do not include, and the client will pay or bear the cost of, any fees, expenses and charges imposed
directly by the mutual funds, CITs, ETFs, and Valley Forge Funds. These fees, expenses and charges are described in
the applicable mutual fund prospectus, CIT prospectus, ETF prospectus, or offering documents or other disclosure
documents of the Valley Forge Funds. These fees will generally include a management fee, other fund, or product
expenses and possibly performance fees. If the fund or product also imposes sales charges, a client may pay an initial
or deferred sales charge. In addition, the client will bear any transaction costs charged by the custodian/brokerage
firm, if applicable.

All fees charged by Third- Party Advisers for SMA management are in addition to our advisory fees and are the
responsibility of the client. Such fees will be described in the SMA account agreement between the client and the
Third-Party Adviser. Clients will also be responsible for transaction, brokerage, trade‐away and custodial fees

incurred by the separately managed account. The client should review all fees charged by Third-Party Advisers, VFIC
and others to fully understand the total amount of fees to be paid by the client.

Generally, upon a client’s written authorization, the custodian for the client’s account directly debits advisory fees
from the client’s account. Prior to deducting fees, VFIC will send the client an invoice showing the amount of the
management fee due, the account value on which the fee is based, and how the fee was calculated. The client shall
instruct the custodian to deliver an account statement directly to the client at least quarterly. This statement shall
reflect all fees deducted from the account. The client is urged to review their custodial account statements for
accuracy, compare them to VFIC’s account statements and contact VFIC and the custodian if the client suspects any
errors. VFIC will receive duplicate copies of the account statements delivered to the client by the custodian.

Upon termination of any client investment management agreement, any prepaid but unearned fees will be refunded
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Item 7. Types of Clients

VFIC provides investment advice to employee benefit plans and their fiduciaries, both high net worth individuals and
other individuals, charitable organizations, corporations, trusts, estates, and other business entities.

VFIC has established certain minimum annual fees which are subject to change. Current minimum annual fees for new
clients are $5,000 for Investment Management Services and $10,000 for discretionary and non-discretionary plan
advisory services. The stated account size minimum for VFIC investment advisory services is $1 million. At the
discretion of the firm, this minimum may be waived to accommodate smaller accounts for family members, trusts, or
institutional investors.