Kahn Financial Group

Michael T. Carey Kahn Financial Group 1700 McMullen Booth RD. Suite A-5 Clearwater, FL 33759 727-797-5551 7/8/2026 . FORM ADV PART 2B BROCHURE SUPPLEMENT This brochure supplement provides information about Michael T. Carey that supplements the Kahn Financial Group brochure. You should have received a copy of that brochure. Please contact David Kahn if you did not receive Kahn Financial Group's brochure or if you have any questions about the contents of this supplement. information about Michael T. Carey is available on the SEC’s website at Additional www.adviserinfo.sec.gov. ©2010 National Compliance Services 800-800-3204  CRD No: 4538404 IARD No.: 134802 Michael T. Carey Form ADV Part 2B Brochure Supplement 7/8/206 Table of Contents Educational Background and Business Experience .................................................... 1 Disciplinary Information ................................................................................................... 2 Other Business Activities ................................................................................................ 2 Additional Compensation ................................................................................................ 3 Supervision ........................................................................................................................ 3 ©2010 National Compliance Services 800-800-3204  Michael T. Carey Form ADV Part 2B Brochure Supplement CRD No: 4538404 IARD No.:134802 7/8/2026 Educational Background and Business Experience Form ADV Part 2B, Item 2 Name: Michael T. Carey Year of Birth: 1958 Formal Education after High School: • none Business Background for the Previous Five Years: • Kahn Financial Group, Inc. Investment Adviser Representative, 09/2005-present • Raymond James Financial Services, Inc. Registered Representative, 09/2005-present Certifications: CERTIFIED FINANCIAL PLANNER™ The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 62,000 individuals have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered in 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and • Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: 1 ©2010 National Compliance Services 800-800-3204  Michael T. Carey Form ADV Part 2B Brochure Supplement CRD No: 4538404 IARD No.:134802 7/8/2026 • Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and • Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® certification. Disciplinary Information Form ADV Part 2B, Item 3 There are no legal or disciplinary events material to a client’s or prospective client’s evaluation of Michael T. Carey. Other Business Activities Form ADV Part 2B, Item 4 Michael T. Carey is a registered representative of RJFS. The registered representatives of RJFS may recommend RJFS to advisory clients for brokerage services. Registered representatives of RJFS are subject to FINRA rules that restrict them from conducting securities transactions away from RJFS. This creates a possible conflict of interests. Clients may utilize the broker dealer of their choice and have no obligation to purchase or sell securities through RJFS. It may be the case that RJFS charges a higher or a lower fee that another broker charges for a particular type of service such as transaction fees. If the client does not use RJFS, Michael T. Carey reserves the right to not accept the account. As a registered FINRA broker dealer, RJFS routes order flow through its affiliated broker dealer Raymond James & Associates, Inc. (RJA). RJA is obligated to seek best execution for all trades executed, but better executions may be available via another broker dealer based on a number of factors including volume, order flow and market timing activity. Michael T. Carey is also a licensed insurance agent with several insurance companies and conducts his insurance and annuity business through Raymond James Insurance Group (RJIG). If a client chooses to use Michael T. Carey in his individual capacity as an insurance agent, he will receive a commission. In certain circumstances this practice gives him an incentive to recommend investment products based on the compensation received, rather than on the client’s needs. 2 ©2010 National Compliance Services 800-800-3204  Michael T. Carey Form ADV Part 2B Brochure Supplement CRD No: 4538404 IARD No.:134802 7/8/2026 Additional Compensation Form ADV Part 2B, Item 5 Michael T. Carey may receive compensation in the form of sponsorship fees for seminars, meetings or conferences from RJFS and from product sponsors such as limited partnerships, mutual fund companies, insurance companies and annuity sponsors. In the case of product sponsors, such fees generally entitle the sponsor to an allotted presentation to him. While this creates a potential conflict of interest, the providers of such benefits are given to understand that this creates no obligation on his part. Supervision Form ADV Part 2B, Item 6 David Kahn supervises Michael T. Carey through regular review of plans prepared for clients and potential clients and reviews his clients’ investments at least on a yearly basis. Discussions occur regularly as to which specific investments have a high likelihood of being of benefit to clients and only investments approved by David Kahn are used. David Kahn also ensures that the training required by RJFS, FINRA, the Florida Department of Insurance and the CFP Board are completed in a timely fashion as well as any other educational program that would assist him in competently assisting his clients. David Kahn is the President of Kahn Financial Group and can be reached at 727-797-5551. 3 ©2010 National Compliance Services 800-800-3204 

Kahn Financial Group 1700 McMullen Booth Rd. Suite A-5 Clearwater, FL 33759 727-797-5551 727-797-5881(fax) www.kahnfinancialgroupinc.com 09/17/2026 FORM ADV PART 2 BROCHURE This brochure provides information about the qualifications and business practices of Kahn Financial Group. If you have any questions about the contents of this brochure, please contact us at 727-797-5551. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Kahn Financial Group is also available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Kahn Financial Group is 134802. Kahn Financial Group is a Registered Investment Adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training.  Material Changes ITEM 2 The material changes in this brochure from the last annual updating amendment of Kahn Financial Group on 03/26/2025 are described below. Material changes relate to Kahn Financial Group’s policies, practices or conflicts of interests. • Kahn Financial Group add information regarding a Wrap Fee Program, Ambassador Program by Raymond James & Associates, Inc. (RJA). (Item 4) • The IMPAC program is no longer available.  Kahn Financial Group Form ADV Part 2A Brochure IARD/CRD No: 134802 SEC File No.: 801- 64112 03/19/2026 Table of Contents Contents Kahn Financial Group AD Part 2 Cover Page ............................................................................................ 1 Material Changes ...................................................................................................................................... 2 Table of Contents ...................................................................................................................................... 3 Advisory Business ..................................................................................................................................... 4 Fees and Compensation ........................................................................................................................... 6 Performance-Based Fees and Side-By-Side Management ........................................................................ 7 Types of Clients ......................................................................................................................................... 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................................... 8 Disciplinary Information ............................................................................................................................. 8 Other Financial Industry Activities and Affiliations ...................................................................................... 9 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................... 9 Brokerage Practices ................................................................................................................................ 10 Review of Accounts ................................................................................................................................. 10 Client Referrals and Other Compensation ............................................................................................... 11 Custody ................................................................................................................................................... 11 Investment Discretion .............................................................................................................................. 11 Voting Client Securities ........................................................................................................................... 11 Financial Information ............................................................................................................................... 12  Form ADV Part 2A, Item 4 Kahn Financial Group (KFG) offers a range of investment advisory services. These services are based on an initial gathering of client information in order to understand the client’s current circumstances and future goals. KFG has been in business since 1999 and is owned by David Kahn. We offer comprehensive financial planning with a focus on retirement and estate planning. We provide portfolio management for individuals and/or small businesses. We request of the client the appropriate financial information, such as current income, assets and liabilities, tax information, etc. We then provide a concise written financial plan that analyzes whether or not the client is on target to reach his/her retirement goals, based on agreed upon assumptions regarding rates of return, inflation, etc. We believe in customizing our advisory services based on the goals of each client, as well as the time frame in which we are operating and the risk tolerance of each individual. While we attempt to achieve an acceptable rate of return for each client, our strategies put a priority on staying within the risk tolerance of each client. We primarily limit our advice to mutual funds. The Ambassador Program is an all-inclusive wrap fee investment advisory account offered by Kahn Financial Group (KFG) and administered by Raymond James & Associates, Inc. (RJA), in which the client is provided with ongoing investment advice and monitoring of securities holdings. This type of account offers clients the ability to pay an asset-based advisory wrap fee in lieu of a transaction fee for each investment transaction within the account. There are no separate transaction fees in Ambassador Program accounts for any type of security. Kahn Financial Group receives the majority of the advisory fee. RJA, as the sponsor of the program, receives a portion of the fee. Charges for other account services provided by Raymond James, not directly related to the advisory, execution, and clearing services provided as part of the wrap fee program may be incurred. Some of these additional expenses could include but are not limited to, safekeeping fees, interest charges on margin loans, and fees for legal or courtesy transfers of securities. The Ambassador Program is offered as both a Discretionary and Non-Discretionary Program. However, KFG chooses to exclusively use the non-discretionary program. For Ambassador Non-Discretionary Program accounts, the IAR will make recommendations to the client, according to their investment objectives, but the client is responsible for all trading decisions. This type of account can be utilized to buy, sell, or otherwise trade stocks, bonds, mutual funds (at net asset value), exchange traded funds (“ETFs”), options, preferred stocks and structured notes and CDs. The client is provided with quarterly portfolio summaries and performance analyses. The overall cost you will incur if you participate in the Ambassador wrap fee program may be higher or lower than you might incur by separately purchasing the types of securities available in the program. You authorize and direct RJA as custodian to deduct asset-based fees from your account and further authorize and direct the custodian to send a quarterly statement to you which shows all amounts disbursed from your account, including fees paid to Kahn Financial Group. Your Ambassador agreement may be terminated by you or us at any time upon providing notice pursuant to the provisions of the agreement. In the event of termination of your agreement, we will refund to you the prorated portion of the fee for the quarter of termination. There is no penalty for terminating your agreement.  Form ADV Part 2A, Item 4 KFG chooses not to manage any assets on a discretionary basis. As of December 2025, assets totaling $122,622,407.00 were being managed on a non-discretionary basis.  Advisory Business Fees and Compensation Form ADV Part 2A, Item 5 The fees KFG will charge for financial planning services are dependent on the anticipated time and complexity of the plan. The fees will be determined in advance and will be disclosed to the client before executing the Investment Advisory Agreement. Fees will rarely depart from the established fee schedule but may do so in exceptional circumstances. It is possible a client will pay more or less for similar services than another client. If a client retains KFG on an hourly basis for plan development or consultation, the rate will range between $100 to $200 per hour (a lesser hourly fee may be charged for administrative and staff functions). If the client retains KFG to create a financial plan on a fixed fee basis, that fee will range between $500 and $4,000, depending on the complexity and comprehensiveness on the plan.  If the cash balance exceeds 20% of the Account Value as of the last business day of the quarter (“the valuation date”) for three (3) consecutive quarterly valuation dates, the amount in excess of 20% is excluded from billing. For those investors who meet the legally mandated net worth requirements to purchase it, private placement life insurance and/or variable annuity policies may be employed, if deemed of benefit to the investor based on the financial planning process. The fee schedule, based on the amount of dollars that are to be placed in such policies are as follows: 1.5% for the first $10,000,000 1.0% for the next $15,000,000 ½% for the next $25,000,000 ¼% for any additional dollars The minimum contribution to such a policy is $1,000,000. Compensation is due in part upon the signing of a separate planning agreement specific to PPLI and/or PPVA and part at the acceptance of the financial plan. The time of payment and the fee itself are negotiable. The annual asset-based fee is paid quarterly in arrears or in advance at the choice of the client. For accounts billed in arrears, the asset-based fee is calculated on the account asset value on the last business day of the quarter for the previous quarter. KFG has the option to bill any management fees on a pro-rata basis for deposits made during a quarter. For accounts billed in advance, the asset-based fee is billed when the account is opened for the remainder of the current billing period based on the initial contribution. Thereafter, the quarterly asset-based fee is paid in advance based on the account asset value on the last business day of the previous quarter and is due the following business day. The client authorizes and directs Raymond James & Associates (RJA) member NYSE/SIPC as Custodian, to deduct asset-based fees from the client’s account. If the client prefers, he may choose to be billed each quarter for the fees due. If paid in a timely fashion, the fees will not be deducted from the client’s account. Clients may incur a nominal charge per transaction for handling and postage. The client may also incur charges for other account services provided by Raymond James Financial Services , member FINRA/SIPC through RJA not deduction related to the execution and clearing of transactions including, but not limited to, IRA custodial fees, safekeeping fees, interest charges on margin loans and fees for legal or courtesy transfers of securities. KFG does not share in any of these additional charges paid to Raymond James Financial Services . Clients should be aware that all mutual funds and insurance products available under the Ambassador program have their own separate management fees and operating expenses, which are disclosed in their respective prospectuses. KFG works primarily with individuals and high net worth individuals as well as pension and profit sharing plans. If fees have been paid in advance and the Investment Management agreement is terminated by providing written notice, the client will receive a refund of the portion of the prepaid asset-based fee which has not been utilized. If a client terminates the agreement within the first five (5) business days of entering into the agreement, all prepaid fees will refunded. The written notice of termination should be sent to: Kahn Financial Group 1700 McMullen Booth Rd. Suite A-5 Clearwater, FL 33759 ©2010 National Compliance Services 800-800-3204  While in most cases the investment advisor representative (IAR) invests the majority of client assets in mutual funds on a fee basis as described above, there are occasions when it is deemed appropriate to use other products that may pay a commission. The different types and amounts of compensation create a conflict of interest. . When making cost comparisons, clients should be aware that the combination of multiple mutual fund investments, advisory services, custodial and brokerage services available through each program may not be available separately or may require multiple accounts, documentation and fees. If an account is actively traded or the client otherwise may not qualify for reduced sale charges for fund purchases, the fees may be less expensive than separately paying the sales charges and fees. If an account is not actively traded or the client otherwise would qualify for reduced sales charges, the fees in these programs may be more expensive than if utilized separately. IARs do not receive a financial incentive to recommend and sell proprietary mutual funds versus non- proprietary funds. However, because compensation structures vary by product type, IARs may receive higher compensation for certain product types. KFG believes the charges and fees offered within the fee-based program are competitive with alternative programs available through other firms and/or investment sources yet makes no guarantee that the aggregate cost of a particular program is lower than that which may be available elsewhere. Clients are free to execute any investment recommendations received from KFG at the broker of their choice and are not required to do so through KFG’s broker RJFS. Far less than 50% of the revenue of KFG is derived from commissions. In certain instances, with certain products a commission is paid initially and for the first year after that the normally applicable fee is waived. Performance-Based Fees and Side-By-Side Management Form ADV Part 2A, Item 6 KFG does not accept performance-based fees. ©2010 National Compliance Services 800-800-3204  Types of Clients Form ADV Part 2A, Item 7 KFG works primarily with individuals, as well as with high net worth individuals. There is a $25,000 minimum account value which can be waived by the firm. Methods of Analysis, Investment Strategies and Risk of Loss Form ADV Part 2A, Item 8 KFG believes that there is no investment without risk. Even a FDIC insured CD may have the risk of the loss of purchasing power over time. Mutual funds, stocks, bonds, alternative investments, etc., can all potentially lose some or all of the client’s investment. As each client has a different tolerance for these risks, the first step in formulating investment advice or in managing assets is determining their specific risk tolerance as well as the time frame for the investment and the goal or goals for the investment. We use a basic risk tolerance questionnaire and follow that up with discussing the above points. We then align the various investments to the result of that analysis. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond (fixed income) nature or stock (equity) nature, or a mix of multiple underlying security types. We believe that mutual funds generally provide an appropriate balance between risk and reward. We analyze each fund we recommend to clients using the data available through subscribing to Morningstar and also using the proprietary mutual fund research of RJFS, as well as by attending various conferences and meeting with fund representatives. We attempt to locate funds with managers that over a period of years often out-perform their peers and their respective indexes. We also believe that a portfolio that is broadly diversified may lower the overall level of risk. To that end, in addition to a core holding of mutual funds, we believe that using alternative investments, for those clients meeting the minimum net worth requirements, will add to the diversification of an investment portfolio. As it is very true that past performance is no guarantee whatsoever of future results, a mutual fund can lose a significant percentage of the funds being managed even if it has not happened in the past. Some alternative investments have varying levels of risk, some quite high with others moderate. We do not engage in frequent trading. We are looking to achieve long term results while primarily avoiding speculative investments. As mentioned above, we believe that while there is still significant risk in using mutual funds as the core holding, especially over a short period of time, the level of risk is moderated through diversification within each fund and through the use of several different funds with different investment objectives. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. ©2010 National Compliance Services 800-800-3204  Disciplinary Information Form ADV Part 2A, Item 9 There are not currently nor have there been in the past any legal or disciplinary events that would be material to a client’s or prospective client’s evaluation of the KFG advisory business or the integrity of our management. ©2010 National Compliance Services 800-800-3204  Other Financial Industry Activities and Affiliations Form ADV Part 2A, Item 10 The Investment Adviser Representatives of KFG are registered representatives of RJFS. Registered representatives of RJFS are subject to FINRA rules that restrict them from conducting securities transactions away from RJFS. This creates a conflict of interests. It may be the case that RJFS charges a higher or a lower fee that another broker charges for a particular type of service such as transaction fees. If the client does not use RJFS, KFG reserves the right to not accept the account. As a registered FINRA broker dealer, RJFS routes order flow through its affiliated broker dealer Raymond James & Associates, Inc. (RJA). RJA is obligated to seek best execution for all trades executed, but better executions may be available via another broker dealer based on a number of factors including volume, order flow and market timing activity. The IARs of KFG are also licensed insurance agents with several insurance companies and conduct their insurance and annuity business through Raymond James Insurance Group (RJIG). If a client chooses to use an IAR in his individual capacity as an insurance agent, the individual IAR will receive a commission. KFG does not recommend or select other investment advisers from which we receive compensation either directly or indirectly. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Form ADV Part 2A, Item 11 KFG has a Code of Ethics, which amongst other points, monitors the personal securities transactions of its employees, officers, directors and IARs. It sets forth standards of conduct and addresses potential conflicts of interest among Kahn Financial Group, its personnel and its advisory clients. Any client may request a copy of the KFG Code of Ethics. This may be done either by phone at 727-797-5551 or by mail at 1700 McMullen Booth RD. Suite A-5 Clearwater, FL 33759. KFG does not have any material interest in any of the securities recommended to clients. The IARs of KFG may invest in the same securities or related securities that they recommend to clients and may recommend securities at the same time that they are buying or selling the same securities. This could create a conflict of interest; however, that is handled by giving priority to client accounts. In the case of mutual funds, the most common security being used for the clients of KFG, all trade prices are determined at the end of the day. Thus, this would not create a conflict of interest. ©2010 National Compliance Services 800-800-3204  Brokerage Practices Form ADV Part 2A, Item 12 KFG receives proprietary RJFS research and third-party research from RJFS. This research is received as a benefit to KFG at no additional cost to KFG. KFG does not have an incentive to recommend RJFS for the purpose of receiving this research. Clients do not pay higher commissions for the purpose of KFG receiving this research. KFG does not consider the receipt of client referrals in recommending RJFS. The IARs of KFG are registered representatives of RJFS, a registered broker-dealer with FINRA, and may recommend RJFS to advisory clients for brokerage services. Registered representatives of RJFS are subject to FINRA Rule 3280 that restricts them from conducting securities transactions away from RJFS. Therefore, clients are advised that such IARs are limited to conducting securities transactions through RJFS. It may be the case that RJFS charges a higher or lower fee than another broker charges for a particular type of service, such as transaction fees. As a registered FINRA broker dealer, RJFS routes order flow through its affiliated broker dealer Raymond James & Associates, Inc. (RJA). RJA is obligated to seek best execution pursuant to FINRA Rule 5310 for all trades executed, however, better executions may be available via another broker dealer based on a number of factors including volume, order flow and market making activity. KFG does not aggregate trades as we do not manage clients’ accounts on a discretionary basis. Each individual is contacted prior to any trade being executed. Review of Accounts Form ADV Part 2A, Item 13 Client accounts are reviewed at least annually to determine if the current investments are performing in an acceptable way, taking into account market conditions at that time. David Kahn, as the principal of KFG, will perform the annual reviews of his personal clients as well as oversee those of any other IAR at KFG. Reviews will also be carried out if we become aware of any significant changes in any clients’ situation or if the economic or investment environment changes significantly in any manner that could necessitate a more timely review. A monthly statement of all client accounts, including asset allocation, performance information and account gains, losses and balances will be sent out by Raymond James & Associates, Inc (RJA). ©2010 National Compliance Services 800-800-3204  Client Referrals and Other Compensation Form ADV Part 2A, Item 14 KFG may receive compensation in the form of sponsorship fees for seminars, meetings or conferences from RJFS and from product sponsors such as limited partnerships, mutual fund companies, insurance companies and annuity sponsors. In the case of product sponsors, such fees generally entitle the sponsor to an allotted presentation to the IARs of KFG. While this creates a potential conflict of interest, the providers of such benefits are given to understand that this creates no obligation on the part of KFG. KFG does not compensate anyone for client referrals. Custody Form ADV Part 2A, Item 15 KFG does not have custody of client funds. It does instruct Raymond James & Associates, Inc (RJA) as to the current fees to be debited from client accounts. KFG follows the safeguarding rules of appropriate jurisdictions. Investment Discretion Form ADV Part 2A, Item 16 KFG does not accept discretionary authority to manage securities on behalf of clients. You are urged to carefully review and compare your account statements that you have received directly from your service provider with any reports you receive from our firm or online services. Voting Client Securities Form ADV Part 2A, Item 17 KFG does not have nor will accept authority to vote client securities. ©2010 National Compliance Services 800-800-3204  Form ADV Part 2A, Item 18 Financial Information KFG does not require or solicit prepayment of more than $500 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure. Item 19: Requirements For State Registered Advisers A. Principal Executive Officers and Management Persons; Their Formal Education and Business Background AAA currently has only one management person/executive officer: First Middle Last. Education and business background can be found on the Form ADV Part 2B brochure supplement for such individual. OR The education and business background of AAA’s current management persons/executive officers, _____ and _____, can be found on the individual’s Form ADV Part 2B brochure supplement. B. Other Businesses in Which This Advisory Firm or its Personnel are Engaged and Time Spent on Those (If Any) Other business activities for each relevant individual can be found on the individual’s Form ADV Part 2B brochure supplement. C. How Performance-based Fees are Calculated and Degree of Risk to Clients AAA does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. OR AAA accepts performance-based fees, fees based on a share of capital gains on or capital appreciation of the assets of a client. ADD PERFORMANCE-BASED FEE SCHEDULE/ DESCRIPTION FROM ITEM 5.A ©2010 National Compliance Services 800-800-3204 Clients that are paying a performance-based fee should be aware that investment advisers have an incentive to invest in riskier investments when paid a performance-based fee due to the higher risk/higher reward attributes. D. Material Disciplinary Disclosures for Management Persons of this Firm