Other Fees
Unless clients direct otherwise or an individual client’s circumstances require, RCA generally recommends that TD Ameritrade Institutional (“TD Ameritrade”) or Fidelity Investments Institutional Services Company, Inc. (“Fidelity”) serve as the broker-dealer/custodian for client investment accounts. Broker-dealers such as TD Ameritrade or Fidelity may charge brokerage commissions and/or transaction fees for effecting certain securities transactions. For example, these custodians may charge commissions for individual equity and fixed income securities transactions or fees may be charged for certain no-load mutual fund transactions. In addition to RCA’s investment management fee, custodial brokerage commissions and/or transaction fees, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses).

Commission Transactions
RCA primarily recommends the purchase of no-load or fee-waived mutual fund securities for implementing investment recommendations. RCA does not actively direct clients to traditional, full service /commission brokers. Most of RCA’s clients do not use traditional brokers. As described earlier, RCA generally recommends using the services of a centralized custodian/discount broker such as TD Ameritrade or Fidelity. However, clients can also elect to engage certain representatives of RCA, in their individual capacities as registered representatives of Triad Advisors, Inc. (“Triad”), an SEC registered and FINRA member broker-dealer to implement investment or insurance recommendations on a commission transaction basis. In the event the client chooses to purchase commissionable investments or insurance products (such as life insurance, long-term care insurance, variable annuities and others) through Triad, Triad will charge brokerage commissions to effect securities or insurance transactions, a portion of which commissions Triad shall pay to RCA’s representatives, as applicable. The brokerage and insurance product commissions charged by Triad may be higher or lower than those charged by other broker-dealers or insurance agents. In addition, Triad, as well as RCA’s representatives, relative to commission mutual fund purchases, may also receive additional ongoing 12b-1 trailing commission compensation directly from the mutual fund company during the period that the client maintains the mutual fund investment. The recommendation that a client purchase any commission product from an RCA representative presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend investment or insurance products based on commissions to be received, rather than on a particular client’s need.

Please Note:
When RCA’s representatives sell an investment or insurance product on a commission basis, RCA does not charge an advisory fee in addition to the commissions paid by the client for such product. When providing services on an advisory fee basis, RCA’s representatives do not also receive commission compensation for such advisory services (except for any ongoing 12b-1 trailing commission compensation that may be received as previously discussed). However, a client may engage RCA to provide investment management services on an advisory fee basis and separate from such advisory services purchase an investment product from RCA’s representatives on a separate commission basis.

No client is under any obligation to purchase any commission products from RCA’s representatives. Clients may purchase investment and insurance products recommended by RCA through other, non-affiliated broker dealers or insurance agents. RCA’s Chief Executive Officer, Daniel C. Kiley, is available to answer any questions that a client or future client may have on this conflict of interest.

Performance-Based Fees — Sharing of Capital Gains
RCA and its supervised persons do not accept performance-based fees.