Fees for personal and EFS to group program Participants are generally negotiated between the adviser and the Sponsor on a case-by-case basis. Fees are usually based upon one or more of the following factors (i) a "per capita" eligible Participant amount, (ii) a "usage by Participants" amount, (iii) the volume of calls by eligible Participants to the NPL, (iv) Participant demand for financial planning software, (v) the number of financial analyses or workshops designed, presented and completed by the adviser, or (vi) other negotiated factors. The adviser's fees in such engagements is paid wholly by the Sponsor. Participants also may incur expenses for fees to any other investment adviser they may consult (unless such expenses are paid for by a Sponsor) and will be responsible for transaction charges imposed by broker-dealers through or with whom they effect transactions for their accounts.