•  Are you registered with the SEC or a state securities regulator as an investment advisor? If so, have you provided me with all disclosures required under those laws (including Part II of Form ADV?)

Heintzberger | Payne Advisors is registered with the Securities and Exchange Commission as an investment advisory firm as Northwest CApital Management, Inc: CRD# 108091, SEC File# 801-56420. We disclose all relationships and sources of income on our SEC Form ADV, which we give to each client before an advisory contract is signed.

•  Do you or a related company have relationships with money managers that you recommend, or otherwise mention to the plan? If so, describe those relationships.

One of the principals of Heintzberger | Payne Advisors has a controlling interest in a third party administration firm, Heintzberger | Payne. Neither Heintzberger | Payne Advisors nor Heintzberger | Payne has any monetary relationship with money managers or other service providers to retirement plans (including custodians, banks, etc.).

•  Do you or a related company receive any payments from money managers you recommend, consider for recommendation, or otherwise mention to the plan for our consideration? If so, what is the extent of these payments in relation to your other income (revenue)?

Heintzberger | Payne Advisors receives no monetary or non-monetary payments whatsoever from money managers or mutual funds. We recommend managers and funds to our clients based on the criteria set forth in their Statement of Investment Policy. In a very few instances, Heintzberger | Payne as a third party administrator does receive Sub-Transfer Agency Fees, all of which are fully disclosed to the Client and itemized as a credit against charges to be paid by the Client or the Plan. The receipt of Sub-TA Fees by Heintzberger | Payne does not increase the revenue Heintzberger | Payne would otherwise have received had no such revenue sharing been paid.

•  Do you have any policies or procedures to address conflicts of interest or to prevent these payments or relationships from being a factor when you provide advice to your clients?

Heintzberger | Payne Advisors and Heintzberger | Payne have written conflicts of interest policies that prohibit the firms and its employees from receiving payments of any kind from money managers, custodians, independent service providers, and other plan consultants. A copy of this policy is available to our clients.

Administrative services provided by Heintzberger | Payne to clients of Heintzberger | Payne Advisors are undertaken pursuant to the statutory exemption to prohibited transactions involving fiduciaries as defined in code section 4875(d)(10). The fees associated with plan administration services are separate from any advisory fee and are provided for under separate contract with Heintzberger | Payne.

•  If you allow plans to pay your consulting fees using the plan's brokerage commissions, do you monitor the amount of commissions paid and alert plans when consulting fees have been paid in full? If not, how can a plan make sure it does not over-pay its consulting fees?

In instances in which brokerage commissions are incurred by a plan, all such trading accounts are custodied with "discount" brokerage firms who will not allocate any of the commission costs to pay plan expenses.

Heintzberger | Payne Advisors does not directly accept 12(b)-1 fees or other types of revenue sharing and does not accept any soft dollars, directed brokerage, commissions, offsets against expenses or research. Relatively few mutual funds Heintzberger | Payne Advisors recommends pay revenue sharing of any sort. Heintzberger | Payne Advisors is fee sensitive and we tend to select funds with low expense ratios.

In some instances, the mutual funds owned by a plan will pay revenue sharing. If excess revenue sharing exists after custodial and administrative expenses have been first deducted (and such transactions itemized and disclosed to the client), such excess can be used to reduce the fees Heintzberger | Payne Advisors is owed providing such payments are made directly from the custodial account and are fully disclosed to the client. Revenues in excess of fees are allocated to the plan as income.

In every instance, a payment of monies to Heintzberger | Payne Advisors or Heintzberger | Payne will generate an invoice to the client fully disclosing the amount and source of the payments.

•  If you allow plans to pay your consulting fees using the plan's brokerage commissions, what steps do you take to ensure the plan receives best execution for its securities trades?

In no instance are commissions being used to pay fees associated with work performed by Heintzberger | Payne Advisors or Heintzberger | Payne. Our efforts to ensure best execution involving commission and transaction costs are driven by our desire to reduce plan expenses versus creating a source of revenue with which to pay plan expenses.

•  Do you have any arrangements with broker-dealers under which you or a related company will benefit if money managers place trades for their clients with such broker-dealers?

Heintzberger | Payne Advisors and Heintzberger | Payne have no monetary arrangements of any sort or affiliations with a broker-dealer. Neither company benefits in any way from the trades Heintzberger | Payne Advisors places.

•  If you are hired, will you acknowledge in writing that you have a fiduciary obligation as an investment adviser to the plan while providing the consulting services we are seeking?

Heintzberger | Payne Advisors acknowledges its fiduciary status in writing within our contract for each client for whom we provide either discretionary or non-discretionary advisory services.

•  Do you consider yourself a fiduciary under ERISA with respect to the recommendations you provide the plan?

Yes, whether we act in a discretionary or non-discretionary capacity. In instances in which we are a discretionary manager, our acknowledgement of fiduciary status is a statutory requirement of ERISA 405(d)(1) if the plan's fiduciary is to claim a relief of liability associated with our acts and omissions for the management of plan assets under our control.

•  What percentage of your plan clients utilize money managers, investment funds, brokerage services or other service providers from whom you receive fees?

In no instance does Heintzberger | Payne Advisors or Heintzberger | Payne receive fees from money managers or other service providers. In all plans, at least one or more mutual funds will pay revenue sharing. However, 100% of all such revenue sharing collected is used as a credit against fees due the custodian, Heintzberger | Payne Advisors and/or Heintzberger | Payne. In no instance does the receipt of revenue sharing increase the fees Heintzberger | Payne Advisors or Heintzberger | Payne would have earned had no revenue sharing of any sort been paid.

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