ACG Wealth Inc

Fees and Compensation
Advisory Fees
ACG is compensated for its advisory services by charging a fee (the “Advisory Fee”) based on the on the market value of a
Client’s Account. The specific manner in which fees are charged by ACG is established in a client’s Account Agreement. Fees
are based on the assets in the account per the fee schedule and in some instances, may be negotiated. The Management
Fee compensates the Adviser and its representatives for the asset management services, investment advice and
recommendations provided. The value of the assets will be based on information provided by the custodian of the assets, the
client or other third party, as applicable. ACG does not independently verify this information nor does ACG guarantee the
accuracy or validity of such information. ACG may reduce or waive the Advisory Fee for some or all Client Accounts for any
period of time determined solely by ACG. Clients may pay ACG more or less than they might otherwise pay if the same
services were purchased through one or more other service providers or investment advisers.
Advisory Managed Account Solutions
The Crest account is a non-“wrap fee” account. A portion of the advisory fees will be paid to Arkadios Capital for brokerage
services provided as described in the Agreement. These brokerage service fees are generally lower than the service fees paid
in connection with the Peak Account. The Crest account is potentially suitable for smaller accounts or in accounts which the
advisor anticipates primarily investing in mutual funds. Crest accounts are custodied with NFS. The basic asset based fee
schedule for the Crest Account is as follows:
             Account Balances                      Annual Fee
               $0 - $500,000                         1.50%
         $500,001 - $2,500,000                       1.25%
       $2,500,001 - $4,000,000                       1.00%
     $4,000,001+                                     0.75%

Existing clients should note they may fall outside the ranges listed above as the basic fee schedule doesn’t take into account
each client’s unique needs and the level of services provided. Further, the client specific fees may be based on a different fee
schedule and will be charged as stated in their advisory agreement.
In place of the fee schedule above, Crest account Clients will be charged a minimum fee of $10.42 monthly, this fee is not in
addition to the asset-based fee schedule but the minimum that a client will be charged. Arkadios Capital, with instructions from
ACG and through NFS, will deduct from the account the minimum service fee, this fee can be verified on the client statement.
The Crest account also has an early termination fee. If the account is closed after five business days, but within the first year,
the Client agrees to pay an early termination fee to cover the administrative costs of establishing the account. The fee will be
based on the number of trades placed on behalf of the account the quarter in which the account is closed. If the account is
closed during the first quarter, the termination fee will be $25 multiplied by the number of transactions in the account. If the
account is closed during the second quarter, the termination fee will be $20 multiplied by the number of transactions in the
account. If the account is closed during the third quarter, the termination fee will be $15 multiplied by the number of
transactions in the account. If the account is closed in the fourth quarter, the termination fee will be $10 multiplied by the
number of transactions in the account. A termination fee will not be charged if this is an ERISA account or no services were
rendered or no trades were placed.

In addition to the advisory fee, Crest accounts will be assessed transaction charges for trades other than mutual fund trades,
such as equities, ETF’s or bonds. These transaction charges may be higher or lower than transaction charges or commissions
charged by other broker-dealers. When appropriate, the Advisor will recommend the purchase or sale of non-mutual fund
securities and the client will pay a transaction fee for those trades. However, mutual funds within this program pay 12(b)-1
service fees (normally 0.25% per year) to NFS. Because Arkadios Capital acts as the Introducing Broker to NFS, those
“indirect” service fees are passed on to Arkadios Capital. This creates an incentive to recommend investment products based
on the compensation received rather than on a client’s needs. Clients have the option to purchase investment products that
we recommend through other brokers or agents that are not affiliated with ACG. Indirect fees received from mutual funds are
considered and anticipated when net fees are set.
These transaction charges have been established to compensate and reimburse Arkadios Capital for its brokerage services
and expenses in executing transactions in program accounts. The transaction charges are negotiated with Arkadios Capital in
conjunction with NFS and may be higher than transaction charges or commissions that a client might pay if the transactions
were executed at another broker-dealer. Arkadios Capital and NFS each receive a portion of the transaction fees paid by
clients. Although transaction charges may be identified as commissions on trade confirmations, the advisor does not receive
any portion of these charges. More details about these fees and charges are discussed in this Brochure and in the client
advisory agreement.
Crest accounts are billed monthly in advance and automatically deducted from the account pursuant to the advisory
agreement and not billed separately to clients. Upon termination of an account, any prepaid, asset-based fees will be prorated
according to the days the account was opened during the calendar quarter and excess fees will be rebated to the client. In
addition, all custodial termination and transfer fees, if any, assessed by NFS will be the responsibility of the client.
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Types of Clients
ACG provides portfolio management services to individuals, corporations and business entities, pension and profit-sharing
plans, charitable institutions, foundations, endowments, estates and trusts. The minimum account size is $50,000. ACG has
the discretion to waive the account minimum.
Methods of Analysis, Investment Strategies and Risk of Loss

Our investment strategy begins with an understanding of a client’s financial goals. Advisors use demographic and financial
information provided by the client to assess the client’s risk profile and investment objective(s) in determining an appropriate
Investment plan for the client’s assets. Investment strategies ordinarily include long- or short-term purchases of equities,
mutual funds, ETFs and fixed income securities.
Investment recommendations are drawn from research and analysis. Security analysis methods typically include the following:
    •    Fundamental analysis: We attempt to measure the intrinsic value of a security by looking at economic and financial
         factors to determine if the company is underpriced or overpriced. Fundamental analysis does not attempt to
         anticipate market movements. This presents a potential risk, as the price of a security can move up or down along
         with the overall market regardless of the economic and financial factors considered in evaluating the stock.
    •    Technical analysis and charting: We attempt to determine the trend of a security by studying past market data,
         including price and volume. This presents a potential risk, as the price of a security can change directions at any time
         and past performance is not a guarantee of future performance.
    •    Cyclical analysis: We attempt to identify the industry cycle of a company to determine whether the company is in a
         market introduction phase, growth phase or maturity phase. Generally projected revenues, growth potential and
         business risk may fluctuate based on the company’s cycle stage.
Information for this analysis may be drawn from financial newspapers and magazines, research materials prepared by others,
annual reports, corporate filings, prospectuses, company press releases and corporate ratings services. ACG adheres to a
long­term, buy­and­hold investment philosophy. While ACG reserves the right to act otherwise if it feels that it is the best
interests of its Clients, ACG does not try to time the market and in general, ACG intentionally does not react to market
movements in managing Client Accounts other than through rebalancing and tax­loss harvesting of managed assets.
Clients should also consider the transactions costs and/or tax consequences that might result from rebalancing. Frequent
rebalancing may incur additional costs and/or tax consequences versus less rebalancing. Rebalancing involves restoring a
client’s original asset allocation by shifting funds among investment categories to regain ratios that may have been decided
initially upon designing a client’s portfolio or decided during the course of their relationship with ACG.
It is important to note that investing in securities involves certain risks that clients must be prepared to bear. Though the goal
of the firm is to find quality investments and proper allocation strategies, there is no guarantee that the goal will be met, and/or
that the value of investor portfolios will not decline in value during any given time period. For any risks associated with mutual
funds and ETFs, please refer to their prospectuses for additional details about these risks. Our investment approach constantly
keeps the risk of loss in mind. These risks include, but are not limited to:
       • Interest-rate Risk: Fluctuations in interest rates cause investment prices to fluctuate. For example, when interest
          rates rise, yields on existing bonds become less attractive, causing their market values to decline.
       • Market Risk: The price of an equity, bond, ETF or mutual fund can drop in reaction to tangible and intangible events
          and conditions. This type of risk is caused by external factors independent of a security’s particular underlying
          circumstances. For example, political, economic and social conditions may trigger market reactions.
       • Advisory Risk: There is no guarantee that ACG’s judgment or investment decisions about particular securities or
          asset classes will necessarily produce the intended results. It is possible that Clients or ACG itself may experience
          computer equipment failure, loss of internet access, viruses, or other events that may impair access to ACG’s
          software based financial advisory service. ACG and its representatives are not responsible to any Client for losses
          unless caused by ACG breaching its fiduciary duty.
       • Volatility and Correlation Risk: ACG’s security selection process is based in part on an evaluation of past price
          performance and volatility to evaluate future probabilities. It is possible that different or unrelated asset classes may
          exhibit similar price changes in similar directions which may adversely affect a Client’s Account and may become
          more acute in times of market upheaval or high volatility. Past performance is no guarantee of future results, and any
          historical returns, expected returns, or probability projections may not reflect actual future performance.
       • Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because
          purchasing power is eroding at the rate of inflation.
       • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially
          lower rate of return (i.e. interest rate). This primarily relates to fixed income securities.
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