Wheeler Retirement Plans LLC

Fees and Compensation

The following types of fees will be assessed:

Asset Management – Fees are charged in monthly or quarterly installments in advance or in
arrears and are based primarily on asset size and the level of complexity of the services provided.
In individual cases, WRP has the sole discretion to negotiate fees that are lower than the standard
fee shown or to waive fees. Fees are not based on the share of capital gains or capital
appreciation of the funds or any portion of the funds. Comparable services for lower fees may be
available from other sources. Fees for the initial month or quarter will be prorated based upon
the number of calendar days in the calendar month or quarter that the advisory agreement is in
effect. In most cases, fees are based on the market value of the assets on the last business day of
the month or quarter. However, certain recordkeepers use the average daily balance as the basis
for advisory fees. WRP has a maximum of 1.00% for all assets under management (“AUM”).

All fees will be invoiced monthly or quarterly to the Plan Sponsor.

As authorized in the client agreement, the account custodian withdraws Wheeler Retirement
Plans LLC’s advisory fees directly from the clients’ accounts according to the custodian’s
policies, practices, and procedures. The custodial statement includes the amount of any fees paid
to WRP for advisory services. You should carefully review the statement from your

custodian/broker-dealer’s statement and verify the calculation of fees. Your custodian/broker-
dealer does not verify the accuracy of fee calculations.

Asset based fees are charged on a monthly or quarterly basis in advance or in arrears. Clients
may terminate investment advisory services obtained from WRP, without penalty, upon written
notice within five (5) business days after entering into the advisory agreement with WRP. The
client is responsible for any fees and charges incurred by the client from third parties as a result
of maintaining the account such as transaction fees for any securities transactions executed and
account maintenance or custodial fees. Thereafter, the client may terminate advisory services
upon written notice delivered to and received by WRP. Clients who terminate investment
advisory services during a month or quarter are charged a prorated advisory fee based on the date
of WRP’s receipt of client’s written notice to terminate. Any earned but unpaid fees are
immediately due and payable, and any prepaid and unearned fees will be immediately refunded.

Fixed Fees

Flat fee accounts are charged in monthly or quarterly installments in advance or in arrears.
There will never be an instance where $1,200 or more in fees is charged six or more months in
advance. Fees are negotiable and vary depending upon the complexity of the client situation and
the services to be provided. Similar financial planning services may be available elsewhere for a
lower cost to the client. Fixed fees for longer-term consulting projects range from $5,000 to
$50,000. WRP will invoice the Plan Sponsor for these type accounts.

Clients may terminate investment advisory services obtained from WRP, without penalty, upon
written notice within five (5) business days after entering into the advisory agreement with WRP.
Thereafter, the client may terminate advisory services upon written notice delivered to and
received by WRP. Clients who terminate investment advisory services during a quarter are
charged a prorated advisory fee based on the date of WRP’s receipt of client’s written notice to
terminate.

Additional Fees and Expenses

In addition to advisory fees paid to WRP as explained above, clients may pay custodial service,
account maintenance, transaction, and other fees associated with maintaining the account. These
fees vary by broker and/or custodian. Clients should ask WRP for details on transaction fees or
other custodial fees specific to their account, as these fees are not included in the annual advisory
fee. WRP does not share any portion of such fees. Additionally, for any mutual funds
purchased, the client may pay their proportionate share of the funds’ distribution, internal
management, investment advisory and administrative fees. Such fees are not shared with WRP
and are compensation to the fund manager. Clients are urged to read the mutual fund prospectus
prior to investing.

Mutual fund companies impose internal fees and expenses on clients. These fees are in addition
to the costs associated with the investment advisory services as described above. Complete
details of such internal expenses are specified and disclosed in each mutual fund company’s
prospectus. Clients are strongly advised to review the prospectus(es) prior to investing in such
securities.

Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that
would not exist if the purchase or sale were made directly with the mutual fund company.
Mutual funds held in broker-dealer accounts also charge management fees. These mutual fund
management fees may be more or less than the mutual fund management fees charged if the
client held the mutual fund directly with the mutual fund company. Clients may purchase shares
of mutual funds directly from the mutual fund issuer, its principal underwriter, or a distributor
without purchasing the services of WRP or paying the advisory fee on such shares (but subject to
any applicable sales charges). Certain mutual funds are offered to the public without a sales
charge. In the case of mutual funds offered with a sales charge, the prevailing sales charge (as
described in the mutual fund prospectus) may be more or less than the applicable advisory fee.
However, clients would not receive WRP’s assistance in developing an investment strategy,
selecting securities, monitoring performance of the account, and making changes as necessary.

Please refer to Item 12 “Brokerage Practices” of this brochure for additional information.
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Types of Clients

WRP offers investment advisory services to plan sponsors for defined benefit pension funds,
profit sharing plans, and defined contribution plans. There is no minimum account size to open
and maintain an advisory account.

Form ADV, Part 2A, Item 8

       Methods of Analysis, Investment Strategies, and Risk of Loss

WRP’s methods of analysis and investment strategies incorporate the client’s needs and
investment objectives, time horizon, and risk tolerance. WRP is not bound to a specific
investment strategy for the management of investment portfolios but rather consider the risk

tolerance levels pre-determined and gathered at the account opening, as well as on an on-going
basis. Examples of methodologies that our investment strategies may incorporate include:

Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix
of asset classes and the efficient allocation of capital to those assets by matching rates of return
to a specified and quantifiable tolerance for risk.

Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount
of securities at regularly scheduled intervals, regardless of the price per share. This will
gradually, over time, decrease the average share price of the security. Dollar-cost averaging
lessens the risk of investing a large amount in a single investment at the wrong time.

Technical Analysis – involves studying past price patterns and trends in the financial markets to
predict the direction of both the overall market and specific stocks.

Long-Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year.

Short-Term Purchases – securities purchased with the expectation that they will be sold within a
relatively short period of time, generally less than one year, to take advantage of the securities’
short term price fluctuations.

Our strategies and investments may have unique and significant tax implications. Regardless of
your account size or other factors, we strongly recommend that you continuously consult with a
tax professional prior to and throughout the investing of your assets.

Investing in securities involves risk of loss that clients should be prepared to bear. Although we
manage your portfolio with strategies and in a manner consistent with your risk tolerances, there
can be no guarantee that our efforts will be successful. You should be prepared to bear the risk
of loss.

All investments involve the risk of loss, including (among other things) loss of principal, a
reduction in earnings (including interest, dividends, and other distributions), and the loss of
future earnings. These risks include market risk, interest rate risk, issuer risk, and general
economic risk. Regardless of the methods of analysis or strategies suggested for your particular
investment goals, you should carefully consider these risks, as they all bear risks.

WRP’s primary goal for investing is to help the client maintain purchasing power over the long
term. This may result in short-term variability and loss of principal. Time horizon and risk
tolerance are key determinates of the proper asset allocation. WRP’s approach focuses on taking
appropriate risks for which clients are compensated (i.e. market risk) and seeking to limit or
eliminate risks that do not provide compensation over the long term (i.e. individual stock risk or
lack of portfolio risk).

Below are some more specific risks of investing:

Market Risk. The prices of securities on which clients invest may decline in response to certain
events taking place around the world, including those directly involving the companies whose
securities are owned by the client or an underlying fund; conditions affecting the general
economy; overall market changes; local, regional or global political, social or economic
instability; and currency, interest rate and commodity price fluctuations. Investors should have a
long-term perspective and be able to tolerate potentially sharp declines in market value.

Management Risk. WRP’s investment approach may fail to produce the intended results. If our
perception of the performance of a specific asset class or underlying fund is not realized in the
expected time frame, the overall performance of client’s portfolio may suffer.

Equity Risk. Equity securities tend to be more volatile than other investment choices. The value
of an individual mutual fund or ETF can be more volatile than the market as a whole. This
volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are
subject to additional risks. Smaller companies may experience greater volatility, higher failure
rates, more limited markets, product lines, financial resources, and less management experience
than larger companies. Smaller companies may also have a lower trading volume, which may
disproportionately affect their market price, tending to make them fall more in response to
selling pressure than is the case with larger companies.

Fixed Income Risk. The issuer of a fixed income security may not be able to make interest and
principal payments when due. Generally, the lower the credit rating of a security, the greater the
risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower
rating, the value of the debt security will decline because investors will demand a higher rate of
return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. A
nominal interest rate is the sum of a real interest rate and an expected inflation rate.

Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and may
be affected by adverse political, legislative and tax changes, as well as by financial developments
that affect the municipal issuers. Because many municipal obligations are issued to finance
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