Services

Asset Management Services

Fresh Bread Investments offers asset management services, which involves Fresh Bread Investments providing you with continuous and ongoing
supervision over your specified accounts. Our asset management services are only offered through our wrap fee program.

You must appoint our firm as your investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of
separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account.

The Account is managed by us based on your financial situation, investment objectives and risk tolerance. We actively monitor the Account and
provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account.

We will need to obtain certain information from you to determine your financial situation and investment objectives. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing
investment restrictions; however we will contact you at least annually to discuss any changes or updates regarding your financial situation,
risk tolerance or investment objectives. We are always reasonably available to consult with you relative to the status of your Account. You have the ability to impose reasonable restrictions on the management of your accounts, including the ability to instruct us not to purchase certain securities.

It is important that you understand that we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions taken for you. We are not obligated to buy, sell or recommend to you any
security or other investment that we may buy, sell or recommend for any other clients or for our own accounts.

Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities
believed to be appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular invest¬ment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obliga¬tion to disclose the information to any client or use it for any client’s benefit.

Fees For Asset Management Services

Fees charged for our asset management services are charged based on a percentage of assets under management, billed in advance (at the start of the billing period) on a monthly or quarterly calendar basis and calculated based on the fair market value of your account as of the last business day of the previous billing period. Fees are prorated (based on the number of days service is provided during the initial billing period) for your account opened at any time other than the beginning of the billing period. If asset management services are commenced in the middle of a billing period, the prorated fee for the initial billing period is billed in arrears at the same time as the next full billing period’s fee is billed.

The asset management services continue until terminated by either party (i.e., Fresh Bread Investments or you) by giving thirty (30) days written notice to the other party. Any prepaid, unearned fees will be promptly refunded by Fresh Bread Investments to you. Fee refunds will be determined on a pro rata basis using the number of days services are actually provided during the final period.

Fees charged for our asset management services are negotiable based on the type of client, the complexity of the client’s situation, the composition of the client’s account (i.e., equities versus mutual funds), the potential for additional account deposits, the relationship of the client with the investment adviser representative, and the total amount of assets under management for the client.  

For our asset management services, clients will be charged the following annual fee based upon the amount of assets under management. 

Assets Under Management

$100,000 – $500,000
$500,001 – $5,000,000
$5,000,001 – $25,000,000
$25,000,001 – $100,000,000
$100,000,001 – $500,000,000
$500,000,001 and Greater

Annual Fees

1.650%
1.350%
1.000%
0.650%
0.450%
0.300%

This is not a “blended” annual fee schedule in which each tier of assets is charged a different rate under the annual fee schedule creating the effect of a blended fee rate used at the time of billing.  Under our fee schedule described above, only one rate is charged against all of the client’s assets under management in this program.

For clients with assets under management of less than $100,000, Fresh Bread Investments has a minimum monthly fee of $90 plus a $200 initial engagement fee. This total annual fee will never exceed 2% of assets under management.

Fresh Bread Investments believes that its annual fee is reasonable in relation to:  (1) services provided and (2) the fees charged by other investment advisers offering similar services/programs.  However, our annual investment advisory fee may be higher than that charged by other investment advisers offering similar services/programs.  In addition to our compensation, you may also incur charges imposed at the mutual fund level (e.g., advisory fees and other fund expenses).

The investment advisory fees will be deducted from your account and paid directly to our firm by the qualified custodian(s) of your account. You must authorize the qualified custodian(s) of your account to deduct fees from your account and pay such fees directly to Fresh Bread Investments.  Our firm will send you a billing statement prior to the time that fee deduction instruction is sent to the qualified custodian(s) of your account.  The billing statement will detail the formula used to calculate the fee, the assets under management and the time period covered.

You should review your account statements received from the qualified custodian(s) and verify that appropriate investment advisory fees are being deducted.  The qualified custodian(s) will not verify the accuracy of the investment advisory fees deducted.

Fresh Bread Investments does not receive any portion of such commissions or fees from you or the qualified custodian. In addition, you will incurcertain charges imposed by third parties other than Fresh Bread Investments in connection with investments made through your account including, but not limited to, mutual fund sales loads, 12(b)-1 fees and surrender charges, variable annuity fees and surrender charges, IRA and qualified retirement plan fees, and charges imposed by the qualified custodian(s) of your account.  Management fees charged by Fresh Bread Investments are separate and distinct from the fees and expenses charged by investment company securities that may be recommended to you.  A description of these fees and expenses are available in each investment company security’s prospectus.

Financial Planning Services

Fresh Bread Investments offers financial planning services, which involve preparing a written financial plan covering specific or multiple topics. We
provide full written financial plans, which typically address the following topics: Investment Planning, Retirement Planning, Education Planning, Asset
Allocation, Risk Management and Estate Planning. When providing financial planning services, the role of your investment adviser representative is to find ways to help you understand your overall financial situation and help you set financial objectives. We also provide modular written financial plans which only cover those specific areas of concern mutually agreed upon by you and us. A modular written financial plan is limited or segmented and does not involve the creation of a full written financial plan. You should be aware that there are important issues that may not be taken into
consideration when your investment adviser representative develops his or her analysis and recommendations under a modular written financial plan. Written financial plans prepared by us do not include specific recommendations of individual securities.

Our financial planning services do not involve implementing any transaction on your behalf or the active and ongoing monitoring or management of your investments or accounts. You have the sole responsibility for determining whether to implement our financial planning recommendations. To the extent that you would like to implement any of our investment recommendations through Fresh Bread Investments or retain Fresh Bread Investments to actively monitor and manage your investments, you must execute a separate written agreement with Fresh Bread Investments for our asset
management services.

Fees For Financial Planning Services

Fresh Bread Investments provides financial planning services under an hourly fee arrangement. An hourly fee of $200 per hour is charged by Fresh Bread Investments for financial planning services under this arrangement. Before commencing financial planning services, Fresh Bread Investments provides an estimate of the approximate hours needed to complete the requested financial planning services. If Fresh Bread Investments anticipates exceeding the estimated amount of hours required, Fresh Bread Investments will contact you to receive authorization to provide additional services. Any unpaid hourly fees are due immediately upon completion and delivery of the financial plan.

To the extent Fresh Bread Investments provides you with investment recommendations as part of the financial planning services and you implement such investment recommendations through Fresh Bread Investments, we may offer in our agreement with you to waive or reduce the fees for financial planning services.

The financial planning services terminate upon delivery of the written financial plan or upon either party providing the other party with 30 days written notice of termination.

In the event that you terminate the financial planning services at any time prior to presentment of the written plan by providing notice to Fresh Bread Investments, there will be no penalty or fees due. For financial planning services performed by Fresh Bread Investments under an hourly arrangement, you will pay Fresh Bread Investments for any hourly fees incurred at the rates described above. In the event that there is a remaining balance of any fees paid in advance after the deduction of fees from the final invoice, those remaining proceeds will be refunded by Fresh Bread Investments to you. If you are not satisfied with the financial plan prepared by Fresh Bread Investments, we may waive our fee; however, in such a situation, Fresh Bread Investments retains intellectual property rights over any written financial plan prepared by Fresh Bread Investments, and the written financial plan must be returned to Fresh Bread Investments.

Advice on Held-Away Accounts

Asset Advisement Services

Fresh Bread Investments offers Asset Advisement Services in the form of consultations, phone calls and reviews which typically address the following topics: Investment Planning, Retirement Planning, Education Planning, Asset Allocation, Risk Management, Estate Planning and Portfolio Reviews. As with financial planning services, the role of your investment adviser representative is to find ways to help you understand your overall financial situation and help you set financial objectives. Our advisement services do not involve the creation of a written financial plan. You should be aware that there are important issues that may not be taken into consideration when your investment adviser representative develops his or her analysis. Our advisement services may include specific recommendations of individual securities, however, it does not include implementing any transaction on your behalf or the active and ongoing monitoring or management of your investments or accounts. These services are primarily reserved for clients that maintain assets at outside brokerage firms or retirement plans and wish to retain an advisor to aid in making investment selections. We do not have investment
discretion or trading authority over your outside accounts.

You have the sole responsibility for determining whether to implement our recommendations. To the extent that you would like to implement any of our investment recommendations through Fresh Bread Investments or retain Fresh Bread Investments to actively monitor and manage your investments, you must execute a separate written agreement with Fresh Bread Investments for our asset management services.

Our Advisement Services include on-going quarterly consultation and account reviews, which cover mutually agreed upon areas of concern related to investments or financial planning. We also offer “as-needed” advisement services, which are limited to a particular investment or financial planning issue raised or request made by you. Under an “as-needed” advisement consultation, it will be incumbent upon you to identify those particular issues for which you are seeking our advice or consultation on.

Fees For Asset Advisement Services

Fees charged for our asset advisement services are charged based on a percentage of assets under management, billed in advance (at the start of the billing period) on a monthly or quarterly calendar basis and calculated based on the fair market value of your account as of the last business day of the previous billing period. Fees are prorated (based on the number of days service is provided during the initial billing period) for your account opened at any time other than the beginning of the billing period. If our advisement services are commenced in the middle of a billing period, the prorated fee for the initial billing period is billed in arrears at the same time as the next full billing period’s fee is billed.

The asset advisement services continue until terminated by either party (i.e., Fresh Bread Investments or you) by giving thirty (30) days written notice to the other party. Any prepaid, unearned fees will be promptly refunded by Fresh Bread Investments to you. Fee refunds will be determined on a pro rata basis using the number of days services are provided during the final period.

Fees charged for our asset advisement services are negotiable based on the type of client, the complexity of the client’s situation, the composition of the client’s account (i.e., equities versus mutual funds), the potential for additional account deposits, the relationship of the client with the investment adviser representative, and the total amount of assets under management for the client.

For our asset advisement services, clients will be charged the following annual fee based upon the amount of assets under advisement.

Assets Under Management

$100,000 – $500,000
$500,001 – $5,000,000
$5,000,001 – $25,000,000
$25,000,001 – $100,000,000
$100,000,001 – $500,000,000
$500,000,001 and Greater

Annual Fees

0.950%
0.750%
0.600%
0.450%
0.300%
0.200%

This is not a “blended” annual fee schedule in which each tier of assets is charged a different rate under the annual fee schedule creating the effect of a blended fee rate used at the time of billing. Under our fee schedule described above, only one rate is charged against all of the client’s assets under management in this program.

For clients with assets less than $100,000 held in an outside account, Fresh Bread Investments has a minimum monthly fee of $60 plus a $100 initial
engagement fee. This total annual fee will never exceed 2% of assets under advisement.

Fresh Bread Investments believes that its annual fee is reasonable in relation to: (1) services provided and (2) the fees charged by other investment advisers offering similar services/programs. However, our annual investment advisement fee may be higher than that charged by other investment advisers offering similar services/programs. In addition to our compensation, you may also incur charges imposed at the mutual fund level (e.g.,
advisory fees and other fund expenses).

The fees for our advisement services can be deducted from your account held away and paid directly to our firm by the outside custodian(s) of your account, using a third-party billing service. You must authorize the custodian(s) of your account to deduct fees from your account and pay such fees directly to Fresh Bread Investments. Our firm will send you a billing statement prior to the time that fee deduction instruction is sent to the custodian(s) of your account. The billing statement will detail the formula used to calculate the fee, the assets under advisement and the time period covered.

You should review your account statements received from your outside custodian(s) and verify that appropriate advisement fees are being deducted. Your outside custodian(s) will not verify the accuracy of the advisement fees deducted.