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Potential Conflicts of Interest

CCAM may recommend securities or investment products to clients in which CCAM or a related person may have some financial interest or buy or sell for itself securities it also recommends to clients. There can be no assurance that advisers acting on behalf of PMP clients will not place transactions in securities which the CCAM principals, in their capacity as a broker-dealer representative, or its related persons, may have an independent financial interest.

CCAM may give advice and take action in performing its duties to clients that may differ from advice given, or the timing and nature of action taken, with respect to PMP accounts. Additionally, CCAM and its principals may be limited in their ability to divulge or act upon certain information in their possession obtained from investment banking or other confidential sources. CCAM, or individuals associated with CCAM, and the PMP investment managers may purchase securities that are recommended to PMP clients. Certain investment managers that CCAM recommends to PMP accounts may direct brokerage commissions to CCAM relating to transactions effected for the account of others.

A portion of the PMP fee described in this brochure will be paid to CCAM financial consultants in connection with the introduction of accounts as well as providing client related services within this program. Such compensation may be more than the financial consultant would receive if clients participated in other programs or paid separately for investment advice, brokerage and other services and, therefore, the financial consultants may have a financial incentive to recommend the PMP over other programs and services.

Capital Consulting and Asset Management, Inc. has adopted and enforces internal policies and procedures with respect to conflicts of interest between Capital Consulting and Asset Management, Inc. and its clients. Pursuant to these policies and procedures, client orders are given precedence over and executed before transactions in which CCAM, or their employees, have an interest.

The client selected advisers in the PMP program provide discretionary portfolio management for client accounts.

PMP is an all-inclusive fee program and generally all brokerage and custody services under the program will be transacted by Fidelity Brokerage Services, Inc. and Charles Schwab & Co., in their capacity as a broker-dealer.

In the event that a client directs CCAM to use a particular broker or dealer other than Fidelity or Charles Schwab, it should be understood that under this circumstance the client will incur the cost of the broker-dealer's commissions and other charges. As a result, the cost of the wrap fee program will be significantly greater than if the services were to be unbundled and purchased separately. In addition, in this circumstance, CCAM will not have authority to negotiate commissions, obtain volume discounts and best execution may not be achieved.

In circumstances where an independent adviser uses a broker other than Fidelity or Schwab, CCAM absorbs any additional commissions and other transaction costs.

The principal executive officer, Rob Nixon, is affiliated with the broker dealer Geneos Wealth Management ("GWM"), and as such, in the separate capacity as a registered representative, may effect securities transactions for compensation.

In addition, Mr. Nixon holds an insurance agent license, which is required in Nebraska in order to evaluate insurance policies and strategies for clients, and may effect transactions in insurance related products for compensation.