Warner Financial Inc

Item 5 – Fees and Compensation.

A. In the event that the Client requests that Warner Financial recommend a broker-dealer/custodian for
   execution and/or custodial services, Warner Financial recommends that investment management
   accounts be maintained at Schwab which is a SEC and FINRA-registered broker-dealer, member SIPC,
   as the qualified custodian. Prior to engaging Warner Financial to provide investment management
   services, the Client will be required to enter into a formal Investment Advisory Agreement with Warner
   Financial setting forth the terms and conditions under which Warner Financial will provide investment
   advisory services, and a separate custodial/clearing agreement with the designated broker-
   dealer/custodian. Warner Financial does not maintain custody of your assets (although we may be
   deemed to have custody of your accounts if you give us authority to withdraw assets from your account
    -see Item 15-Custody, below). We are independently owned and operated and not affiliated with
    Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we
    instruct them to.

     We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms
     that are overall most advantageous when compared with other available providers and their services.
     Factors that Warner Financial may consider in recommending Schwab (or any other broker-
     dealer/custodian to Clients) include, among others:

     •    combination of transaction execution services along with asset custody services (generally without
          a separate fee for custody);
     •    capability to execute, clear and settle trades (buy and sell securities for Clients’ accounts);
     •    capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests,
          bill payment, etc.);
     •    breadth of investment products made available (stocks, bonds, mutual funds, exchange traded
          funds, etc.);
     •    availability of investment research and tools that assist Warner Financial in making investment
          decisions;
     •    quality of services;
     •    competitiveness of the price of those services (commission rates, margin interest rates, other fees,

Warner Financial, Inc.                                                                        Disclosure Brochure

           etc.) and willingness to negotiate them;
       •   reputation, financial strength and stability of the provider;
       •   their prior service to Warner Financial and Warner Financial’s other Clients; and availability of other
           products and services that benefit Warner Financial, as discussed below.

       For our Clients’ accounts that it maintains, Schwab generally does not charge you separately for custody
       services, but is compensated by charging you commissions or other fees on trades that it executes or
       that settle in your Schwab account. To the extent that a transaction fee will be payable by the Client to
       Schwab, the transaction fee shall be in addition to Warner Financial’s investment advisory fee referenced
       in Item 5 above.

       To the extent that a transaction fee is payable, Warner Financial shall have a duty to obtain best
       execution for such transaction. However, that does not mean that the Client will not pay a transaction
       fee that is higher than another qualified broker-dealer might charge to effect the same transaction where
       Warner Financial determines, in good faith, that the transaction fee is reasonable. In seeking best
       execution, the determinative factor is not the lowest possible cost, but whether the transaction represents
       the best qualitative execution, taking into consideration the full range of a broker-dealer’s services,
       including the value of research provided, execution capability, transaction rates, and responsiveness.

       1. Research and Additional Benefits
          Although not a material consideration when determining whether to recommend that a Client utilize
          the services of a particular broker-dealer/custodian, Warner Financial may receive from Schwab (or
          product/fund sponsor) without cost (and/or at a discount) support services and/or products, certain
          of which assist Warner Financial to better monitor and service Client accounts maintained at such
          institutions. The support services that Warner Financial may obtain could include: investment-related
          research, pricing information and market data, software and other technology that provide access to
          Client account data, compliance and/or practice management-related publications, discounted or
          gratis consulting services, discounted and/or gratis travel and attendance at conferences, meetings,
          and other educational and/or social events, marketing support, computer hardware and/or software
          and/or other products used by Warner Financial in furtherance of its investment advisory business
          operations.

           Warner Financial’s Clients do not pay more for investment transactions effected and/or assets
           maintained at Schwab as a result of this arrangement. There is no corresponding commitment made
           by Warner Financial to Schwab or any other entity to invest any specific amount or percentage of
           Client assets in any specific mutual funds, securities or other investment products as a result of the
           above arrangement.

           Warner Financial’s Chief Compliance Officer, Barbara Warner, is available to address any
           questions that a Client or prospective Client may have regarding the above arrangements
           and the corresponding conflict of interest presented by such arrangements.

       2. Warner Financial does not receive referrals from broker-dealers.
...

Item 7 – Types of Clients

 Warner Financial generally provides investment advice to the following types of Clients.

      •    Individuals (including Trusts and Estates)
      •    High-Net Worth Individuals
      •    Pension and profit sharing plans
      •    Charitable Organizations

 All Clients are required to execute an agreement for services in order to establish a Client arrangement with
 Warner Financial.

Minimum Investment Amounts Required: Warner Financial typically requires an initial minimum
investment amount of $1,000,000 for its Asset Management Services. Warner Financial, in its sole discretion,
may waive its portfolio minimum, charge a lesser investment advisory fee and/or charge a flat fee based upon
certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount of
assets to be managed, related accounts, account composition, competition, negotiations with Client, etc.). As
result of the above, similarly situated Clients could pay different fees. In addition, similar advisory services
may be available from other investment advisers for similar or lower fees.

ANY QUESTIONS: Warner Financial’s Chief Compliance Officer, Barbara Warner, remains available
to address any questions that a Client or prospective Client may have regarding advisory fees.

 Warner Financial, Inc.                                                                         Disclosure Brochure