Vestgen Investment Management LLC

Item 5. Fees and Compensation
VestGen provides investment management services for an annual fee based upon a percentage of the
market value of the clients’ assets being managed by VestGen.

VestGen’s standard fee schedule is as follows:

                      Portfolio Value                                      Base Fee
                      Up to $500,000                                       2.20%, then
                      From $500,000 - $1,000,000                           1.85%, then
                      On $1,000,000 and Above                              1.25%

VestGen reserves the right to charge a different management fee, no greater than 2.20% annually, on
any account value, in its sole discretion, as agreed to by the client.

Clients pay the investment management or advisory fees noted above which includes investment
management services comprised of client profiling assistance, asset allocation assistance, research and
evaluation of Model Managers and account performance, Model Manager hiring and termination, fee
billing, account rebalancing, account reporting, and other operational and administrative services. It
should be noted that the investment management fees may or may not include Model Manager fees,
custodial transaction fees or investment advisory fees, all of which may be assessed against a client’s
account. VestGen’s Platform accounts include brokerage, variable insurance, and sub-advised
arrangements.

The fee assessed by VestGen varies based upon the services an adviser and their firm have selected
and will be outlined in the agreement between VestGen and the firm. Generally, VestGen’s fee will
not exceed 2.20% per annum. If the client account was introduced to VestGen by a Co-Adviser or
Promoter, VestGen will share a portion of their fee with the Co-Adviser or Promoter’s firm pursuant
to an agreement between VestGen and the firm. VestGen’s fees are typically calculated on a per
account basis. Mutual funds, ETFs and alternative investments charge their own fees for investing the
pool of assets in the respective investment vehicles. Please see the prospectus or related disclosure
document for information regarding these fees.

Model Manager Fees:

The Platform fee or investment management fee does not include the fees for the Model Manager’s
services (“Model Manager Fee”). The Model Manager Fee is separate and distinct from the Platform
fee, custodial fees, and investment management fees. Model Manager Fees vary based on the manager
selected. The Model Manager Fee is calculated based on the account assets invested in the model.
Model Manager Fees typically range from 0.0% to 0.35% but may be higher and will be disclosed to
the client at the time of account opening. As part of its services, VestGen may collect fees on behalf
of the Model Manager. In addition, VestGen may collect administrative fees from Model Managers
for administration of the models, due diligence, etc.in its Platform.

Retirement Platforms:

The annual management fee charged by VestGen along with the collection and timing of fees is
described in the written agreement between VestGen and the qualified plan and/or plan participant.

VestGen’s role and responsibilities are detailed in the terms of the agreement between VestGen and
the qualified plan and/or plan participant. Examples of VestGen’s responsibilities include creating and
managing models for participants, selecting, and managing the Core Funds to be made available to
plan participants, or managing Qualified Default Investment Alternative accounts (“QDIA”).
Management fees for these services range from 0.10% to 0.65% of assets under management.
Depending on the services provided, VestGen could receive this management fee based on the value
of individual participant accounts or on the total value of the plan. VestGen has reduced its
management fee for instances where VestGen has recommended that the VestGen Mutual Funds are
part of the plan’s investment options.

Sponsored Investment Management Platforms or Investment Programs:

Per the written agreement by VestGen and a program sponsor, VestGen may receive an annual fee
between .30% to 0.50% of the market value of the assets it provides services on. The exact fee
calculation and timing of the fee to be charged will be determined by the program sponsor. The
program sponsor will calculate and deduct the appropriate fees from the client account and remit those
fees to VestGen. For a complete description of the Sponsored Investment Management Platform or
Investment Program fees refer to the program sponsor’s Appendix 1 of Form ADV Part 2A.

Investment Company Management:

VestGen charges the fees described in the applicable advisory or sub-advisory agreement to the extent
consistent with applicable laws and the offering documents of the investment company client.
Generally, for investment company clients, VestGen receives approximately 1.00% of assets under
management from the VestGen Mutual Fund.

Charges and Fees by Third Parties

Clients may be charged certain fees and expenses imposed by third party broker-dealers, insurance
companies, investment companies and/or custodians such as custodial fees, charges imposed directly
by a mutual fund, ETF or CIF in the account, which are disclosed in the fund’s prospectus (e.g. fund
management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes,
wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions. Such charges fees and commissions are exclusive of and in addition to VestGen’s fee.

Fees for Management during Partial Quarters of Service

When a client engages VestGen to provide investment management services, the fees are calculated
on a pro rata basis for the initial period. VestGen’s investment management services will continue until
terminated by VestGen or the client pursuant to the written agreement.
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Item 7. Types of Clients
VestGen provides its services to individuals, investment companies, pension and profit-sharing plans,
trusts, estates, charitable organizations, corporations and business entities.

Minimum Account Size

A condition for starting and maintaining a relationship with VestGen is generally a portfolio size of
$50,000. VestGen makes an exception for qualified plans in which VestGen has been hired by the
qualified plan or participant to serve as the investment adviser. VestGen reserves the right to accept
clients with smaller portfolios based upon certain criteria including anticipated future earning capacity,
anticipated future additional assets, account composition, related accounts, and pre-existing clients.
VestGen only accepts clients with less than the minimum portfolio size if, in the sole opinion of
VestGen, the smaller portfolio size will not cause a substantial increase of investment risk beyond the
client’s identified risk tolerance. At its sole discretion, VestGen may allocate the client’s assets to a
smaller number of underlying securities to effectively manage the Model strategy and may decide to
reallocate the client’s assets to the complete Model holdings when VestGen deems the timing to be
appropriate. This variation from the Model portfolio may contribute to performance deviation,
including under performance. VestGen may aggregate the portfolios of family members to meet the
minimum portfolio size.