The fee schedules for the Compass Account programs are as shown on Schedules D, E and F within the Compass Agreement. Methods of Compensation Thurston Springer will base fee charges on 1) One of three fee schedules and/or 2) A flat fee rate and/or breakpoint and/or 3) An hourly rate. Depending on various factors, advisory fees are negotiable. Minimum annual fees apply as follows: $600 for a Mutual Fund Account, and $1,200 for an Individual Securities account. A breakpoint is defined as a dollar amount discount that qualifies the client for a reduced fee, even though the actual amount of assets managed may be lower. The Fee Schedules for advisory services have been outlined on the charts within the Compass Account Agreement. If an account value falls below the minimum account value criteria, and the Client has no other assets to add to the account, and no other accounts which to combine for purposes of meeting the minimum account value, Thurston Springer advises the Investment Advisor Representative to evaluate changing the account from a fee-based to a commission-based account. Flat fee Rate. You are able to choose a flat rate instead of a fee schedule. When a flat rate is selected, the flat rate is a fixed charge, and any reference to householding or to asset type discounts does not apply. Hourly fees include non-continuous advice that a client requires for a particular situation. This Agreement does not capture information relating to an hourly fee amount nor a description of the services provided for the hourly fee. When an hourly fee is to be charged, the Advisor Representative will use the Financial Planning Engagement Agreement to disclose the fee and services to be provided. Advisor Representatives also provide consultation services on various matters such as Retirement Plan Consulting, Net-Worth Accumulation, Household Money Management, Portfolio Manager Selection, and/or Individual 401(k), or 403(b) Review or Management. For example, a client may want their Advisor Representative to review their 401(k) account that is held through their employer in order to take a holistic approach to managing their entire investment portfolio. Providing such review could give the Advisor Representative the opportunity to alert the client to a lack of diversification, an over-concentration, expensive assets, risky investments, and such. A fee will be charged for this extra service. The fee will be assessed by charging an hourly rate or increasing the annual fee. The additional service fee will be waived or reduced to the extent that a client uses Thurston Springer for brokerage or advisory services. Client can terminate these services in writing at any time and request a refund of the unused portion of the fee. Features of the Compass Account Wrap Program that Comprise the Costs of the Account A. The Compass Account is a wrap-fee program, providing portfolio management services. There are four managed model account programs available including: 1. Managed Mutual Fund Portfolio composed of mutual funds only, and, 2. Individually Managed Securities Portfolio, which is composed of stocks, bonds, mutual funds, exchange traded funds, and other investments, 3. Tactical Momentum, and 4. Earnings Momentum. Selection of the portfolio manager includes: 1. The Advisor Firm: Thurston Springer; or 2. The Advisor Representative: your Financial Advisor The choice as to whether or not the client pays a ticket charge per transaction is based on the anticipated trading activity in the account: 1. When ticket charges are paid by the client, the fee could be lower than a model in which ticket charges are not paid by the client. 2. When ticket charges are not paid by the client, the fee could be higher than a model in which ticket charges are paid by the client. In summary, the over-all cost of the fee-based account is based on the managed model account profile selected, the account type that is selected, as well as how many transactions are expected to be executed, and how charges are handled. B. Over-all Cost: The Advisory Program could cost more or less than paying for transactions separately. Although potentially lower cost account options are available, Client acknowledges and agrees that choosing a fee-based account is primarily based on a relationship in which their Advisor Representative actively manages and/or monitors their account holdings. Client’s advisory fee could be higher or lower for similar services offered by other Advisor Representatives at the same advisor firm, as well as at other investment advisor firms. C. Client pays Advisor a fee for providing portfolio management services. The advisory fee is assessed as a percentage of the assets under management (AUM) in accordance with the fee schedule selected for Client’s account or a base or flat rate and is paid at the end of each calendar quarter. If an account falls below the minimum AUM, Thurston Springer reserves the right to assess a minimum fee that is disclosed in the Compass Account Agreement. Despite the investment allocation deployed in a client’s account, the client will never be fully invested, as Thurston Springer will always ensure a portion of the account is available as cash to cover advisory account fees. Where a client has multiple accounts under management and certain of those accounts do not have the ability for fees to be withdrawn, such as an IRA or 401k, Thurston Springer will ensure that an account which has the ability to withdraw funds without penalty or tax implications will have sufficient free cash to cover the account fees across all client accounts under management. In summary, the over-all cost of the fee-based account is based on the Managed Model Account Profile selected, the account type that is selected, the number of anticipated transactions, as well as how charges are

handled. Wrap Fee Programs Thurston Springer manages a Wrap Fee Program of its own, the Compass Account. Thurston Springer, in its capacity as the advisor firm is paid for its services in managing the program, for back-office duties, and such. The firm receives a portion of the wrap fee for our investment advisory services and will also charge a transaction fee for broker-dealer services to offset the cost of each transaction. If your Advisor Representative were to arrange for the investment and management of your assets at an outside advisor firm, that firm would also be paid for providing portfolio management services, and our firm would receive a portion for our services. Thurston Springer as the investment advisor firm receives a portion of the wrap fee for investment advisory services provided, which varies between 3 and 24 basis points (.03 to .24), depending on the model chosen. The advisory account fee will be 1) directly deducted from client’s account, 2) or paid by the client by way of a check, or 3) directly deducted from a different brokerage or advisory account. When the fee is deducted from client’s internal account, the advisory fee will be debited from the specified account on the payment date. Client may also pay the advisory fee from outside funds provided that Advisor is so notified in advance and such outside funds, sufficient to pay this fee, are paid to Advisor on or prior to the payment date. Other types of charges or expenses clients will pay in connection with the Compass Account include: Advisory account fees are exclusive of transaction fees and other related costs and expenses. Clients will incur certain charges imposed by custodians, brokers, and third parties, such as fees charged by managers, custodial fees, odd-lot differentials, transfer taxes, postage and handling, electronic funds fees, and other fees and taxes on brokerage accounts and securities transactions. These fees are usually small and are incidental to the importance of the security being purchased or sold.
• Ticket charges per transaction will be passed on to the client depending on the Compass Account model selected. (See Compass Account Selection for transaction charge information) However, there are brokerage transaction charges that apply to all accounts, regardless of whether the account is commission based or fee based.
• Mutual funds and exchange-traded funds charge internal management fees, which are disclosed in a fund’s prospectus.
• ETFs (Exchange Traded Funds), and bonds will be billed using the corresponding fee schedule.
• Fixed income assets such as CDs (certificates of deposit), treasuries or individual bonds, taxable or tax-free, will be purchased and sold on a net basis with no mark-up or mark-down.
• Cash in stock accounts will be billed the same rate as stocks; cash in fixed income accounts will be billed the same rate as bonds; and cash in mutual fund accounts will be billed the same rate as mutual funds. If an account has various assets, the cash will be billed proportionately to the invested assets.
• If margin is used in the account, the fee will be based on the market value of the securities. Thurston Springer charges on gross value of assets under management, not on net value.
• Liquidations: When securities are deposited into the account, they will be liquidated at the discretion of the Advisor Representative/Portfolio Manager in order to select the investments he/she has determined are appropriate for your Account. The standard management fees for the asset class will apply. A large position might be sold over time in an attempt to maximize the value of the account. Realizing that the stock price might decline, Client acknowledges the risk inherent in such a strategy.
• Thurston Springer is also able to select load-waived (no sales charge) funds and funds designed specifically for wrap accounts with no sales charge. D. It is Thurston Springer’s wholehearted intent to bring each client the best value in their relationship with our firm and representatives. The specific manner in which fees are charged is established in a client’s written advisory agreement. Advisory fees are charged based on assets in the account at the end of each calendar quarter. Clients may elect to be billed directly for fees, or to authorize fees to be debited from their accounts. Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee. Either party may terminate the agreement at any time by written notice. Upon receipt of notice from the Client (or authorized representative of the Client), Thurston Springer will consider the Agreement to be terminated. Advisor and Custodian reserve the right to finish any open transactions and collect any earned and unpaid fees that are due and payable. Services to be provided will include portfolio selection, execution services relative to all purchases and sales transactions and arrangement for custody services through the Advisor’s clearing firm, First Clearing Corporation, located in St. Louis, Missouri. Depending on your circumstances and activity, Client could pay more for this program than s/he would if the client participated in a brokerage account or paid an hourly fee for investment advice. Advisor Representative receives compensation as a result of Client’s participation in this program. The amount of this compensation could be more than what the person would receive if the Client paid separately for investment advice, brokerage, and other services. Therefore, the Advisor has a financial incentive to recommend this program over other services. Thurston Springer subscribes to the Code of Ethics, both by the letter, and in the spirit of which it is mandated that customer interests shall always be placed above those of the Advisor. Clients have the ability to purchase investment products that we recommend through other brokers or agents that are not affiliated with our firm.