Westminster Financial Advisory Corp

Item 5 – Fees and Compensation

Fees are calculated as a percentage of assets under management. Accounts are charged in advance or
arrears for a three-month period based on the account balances. Accounts are debited for the
appropriate fee. If you have multiple accounts, you may request the company bill all management fees
to one account. For initial periods, the beginning balance and date range is described by the
management contract. When an account is first placed under management, billing begins on the later
of, first day the account is funded or the first day the account is approved by the company. In addition
to our standard fees, you may incur other charges from other parties for clearing, custody, independent
investment management, advisory services or other services that may be provided on an hourly basis. If
outside consultants are required for additional analysis and advice, the resulting cost will increase the
amounts disclosed in the below fee schedule and will be payable directly to those outside consultants.
Mutual fund managers, money fund managers, and annuity issuers charge certain fees for their services
and products. Those fees are in addition to the management fees paid to the Adviser and are separate
and distinct from the management fees charged by the Adviser. These fees and expenses are described

in the prospectuses for each mutual fund, money fund, annuity, or underlying annuity fund. These fees
include front-end or back-end loads (initial or deferred sales charges), management fees, other fund
expenses and distribution fees (“12b-1 fees”). The type of mutual fund share class used in client
portfolios will determine if there is an initial or deferred sales charge which a client will pay, as well as
the existence and amount of other fund or product expenses to be paid by the client. These charges,
fees and expenses will impact the cost to the client of purchasing, holding and/or selling the mutual
fund or annuity product. Many mutual fund share classes pay 12b-1 fees or trailing commissions to our
affiliated Broker/Dealer, Westminster Financial Securities, Inc., which increases the cost to the client of
holding the mutual fund. This fee is generally .25% annually but varies from fund to fund. In many
instances, a portion of these trailing commissions are then paid to the investment adviser representative
who is also a registered representative of the Broker/Dealer. Many money funds pay a share of their
revenue to our affiliated Broker/Dealer, Westminster Financial Securities, Inc., which reduces the
interest rate paid to the client for holding the money market fund. This fee varies from fund to fund. In
some instances, a portion of the revenue share is then paid to the investment adviser representative
who is also a registered representative of the Broker/Dealer. Such payments create an incentive for the
investment advisor representative to recommend, purchase and hold a higher-cost share class, which
creates a conflict of interest. In certain instances, lower-cost mutual fund share classes are available.
Accordingly, the client should review both the fees charged by the funds and the applicable program fee
charged by the Adviser to fully understand the total amount of fees to be paid by the client and to
thereby evaluate the Advisory services being provided.

The advisory fee is determined based on the fair market value of the client’s account on the last day of
each closing calendar quarter multiplied by one-fourth of the corresponding annual percentage rate
pursuant to the terms of the investment advisory agreement. The annual percentage rate is negotiable
based on several factors, including, but not limited to the services offered to the client, the complexity
of the services to be provided, the total amount of assets involved in the household*, and the
relationship with the advisor. The annual advisory fee will not exceed 2.5% of the managed account
value, and the negotiated rate is identified in the investment advisory agreement.

Clients may be charged a commission and/or service fee for trades executed in their account. The
commission and service fee are negotiable, and will vary by client, account, and advisor. Each advisor
negotiates their financial arrangement with the firm individually and that financial arrangement is the
basis for fees charged to the clients. In many instances, the transaction fees are retained by the firm
and/or advisor rather than a pass through of fees charged to execute the transaction. This revenue
source creates an incentive for the firm or advisor to execute trades which creates a conflict of interest.
The negotiated transaction fees are documented on the investment advisory agreement.

*Westminster Financial Advisory Corporation defines a household as any number of people sharing a
residence, or members of the same nuclear family regardless of residence.

A client may terminate an agreement within five business days after signing, without penalty. After the
five-day period expires, a client may terminate a contract by written notice and any fees earned are
non-refundable.

Assets deposited by a client into their management account between billing cycles will not result in
additional management fees being billed to the client. For assets withdrawn by a client, Westminster
Financial Advisory Corporation does not make partial refunds of their management fees. Just as with
deposits, withdrawals may require modifications and adjustments to be made in the account to correct
the client’s allocation of assets.

Your advisor may have a financial incentive agreement in place to receive additional compensation
based on a combination of assets transferred to Westminster Financial Advisory Corp. and revenue
generated, which presents a conflict of interest. Your advisor may be incentivized to transfer accounts
to Westminster or generate higher revenue, which may not be in the client’s best interest. If a financial
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Item 7 – Types of Clients

Westminster Financial Advisory Corporation has registered financial advisors focused on assisting
individuals and their families, trusts, estates, fiduciaries, charitable organizations, small businesses, and
retirement plans (hereinafter referred to as the “client”) manage their wealth and comprehensive
financial plans. Our central duty is to provide investment counsel and guidance which stresses fiscal
responsibility and disciplined asset allocation strategies to meet client needs, goals, and risk tolerance.