Wespac Advisors LLC

Item 5 - Fees and Compensation

       A. Our investment advisory fees are based on an annual percentage of client assets under our
       management. Our maximum fee schedule is as follows:
               Portfolio       Annual
               Asset Value     Fee Rate
       First   $1,000,000      1.25%
       Next    $1,000,000      1.15%
       Next    $1,000,000      1.05%
       Next    $2,000,000      0.95%
       Over    $5,000,000      0.85%

       Our fees are negotiable and may be waived in certain circumstances, as in the case of em-
       ployee accounts. Our investment advisory fee includes any advisory fees of any sub-advisers;
       that is, we pay any sub-advisers directly from the advisory fees paid to us.

       B. Clients typically grant us authority to deduct our fees directly from client’s account. However,
       we will also bill directly for fees if that is a client’s preferred option. Fees are billed quarterly in
       advance and calculated based on the market value (provided by each client’s independent

WESPAC Advisors, LLC                                                                                      Page 5 of 17

       custodian) of each client account as of the last day of the applicable quarter. Cash, accrued
       interest, and the value of any securities held on margin are included for billing purposes, unless
       we determine otherwise, in our discretion.
       In situations where a new retirement plan client is engaged and customer funds are transferred
       in at various points during the first quarter of engagement, we have a slightly different method
       of calculating fees. Here we would use the weighted average of the monthly balances during
       the quarter and then pro-rate it based on the number of days money was in the account. We
       are using this method so as not to overly penalize a client if a large conversion balance is
       transferred in near the end of a quarter. The following is an illustration:

        Balance as of:           Scenario 1                  Scenario 2              Scenario 3
                 1/31/2013       $ 3,500.00                          -                        -

                  2/28/2013      $ 7,000.00                   $ 7,000.00                      -

                  3/31/2013      $ 325,000.00                 $ 325,000.00            $ 325,000.00
                                 $ 335,500.00                 $ 332,000.00            $ 325,000.00

        divided by # of months   $ 111,833.33                 $ 166,000.00            $ 325,000.00
        Date money first enters
                   the account           1/15                      2/15                     3/15
        Fee would =           (76/90*.001875*$111,833.33)
                                  $ 177.07                    $ 155.63                $ 108.33

       C. In addition to our fees, clients are responsible for fees, expenses and charges imposed by
       third parties in connection with the investment and maintenance of their assets. These fees,
       expenses and charges could potentially include brokerage commissions or securities transac-
       tion fees and other expenses and charges imposed by the client’s custodian and/or broker-
       dealer, or custodial fees. Investment companies (mutual funds, ETFs, etc.) in which a client’s
       assets may be invested charge additional management fees and other expenses as described
       in the fund’s prospectus. Please also refer to Items 12-15 of this Brochure for more information
       regarding our brokerage and trading practices.

       D. Because we charge our fees in advance, any clients who terminate our advisory services
       during a quarter will receive a pro-rata refund for any unused pre-paid portion of any advisory
       fees based on how many days remain in that calendar quarter. The pro-rata refund is calculated
       from the date we receive a notice of termination.

       We offer clients the option of obtaining cash management solutions from unaffiliated third-
       party financial institutions through Flourish Financial LLC (“Flourish”). No Focus affiliate will
       receive any compensation from Flourish that is attributable to our clients’ transactions. Further
       information on this conflict of interest is available in Item 10 of this Brochure.

       Supervised persons of the Firm from time-to-time receive typical and customary commissions
       from the recommendation and sale of insurance products. One of our related persons is a li-
       censed agent of a WA affiliate, WESPAC Benefit & Insurance Services, LLC (“WBIS”), an
       insurance brokerage firm. To the extent that a client purchases insurance the related person
       recommends, WBIS and/or the related persons will receive commission from the applicable
       insurance company. Advisory clients should understand this represents a conflict as there is an

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       incentive for these persons to recommend products for which they receive compensation. We
       address this conflict through disclosure and make recommendations we reasonably believe to
       be in the best interests of its clients. Additionally, advisory clients are under no obligation to
       utilize these services. Our related persons are prohibited from selling insurance products to
       clients where such sale would be deemed a Prohibited Transaction under ERISA.

Item 7 - Types of Clients

       We advise a variety of client types, including plan sponsors of self-directed and trustee-directed
       retirement plans, individuals, testamentary trusts, corporations and other forms of business
       entities.

       We usually require prospective clients who are individuals or trustee-directed retirement plans
       to have a minimum of $250,000 to invest with us ($5,000 if the client is a self-directed retire-
       ment plan) but retain the discretion to waive the minimum under appropriate circumstances.