Alchemi Wealth LLC

Fees and Compensation - Item 5

 Investment Management Services Fees

                 Assets Under Management                       Annual Fee (%)
                 $0 to $499,999                                1.50%
                 $500,000 to $2,499,999                        1.25%
                 $2,500,000 to $4,999,999                      1.00%
                 $5,000,000 and above                          0.75%

 Minimum Account Size: Alchemi does not have an account minimum.

 Fees are negotiable. Fees may differ based on a number of factors:

     •    Size of the relationship – Larger accounts may receive more favorable pricing.
     •    Accounts within the same household may be combined for a reduced fee.
     •    Level of services needed – Accounts requesting more services may have higher fees.
     •    Trading activity and active portfolio management – actively managed accounts generally have higher
          fees than fixed income accounts, buy and hold portfolios, and mutual fund or exchange traded fund
          accounts.
     •    Accounts with conservative allocations may negotiate lower fee schedules.
     •    Our employees and their family related accounts are charged a reduced fee for services.

 For held away assets managed through Pontera, Pontera does not offer us the ability to deduct fees from the
 account. As such, fees for the management of held away assets will either be paid directly by you or deducted
 from another account that we manage for you at the qualified custodian(s) recommended by us. Fees for accounts
 managed through Pontera will be based on the value of the account on the last day of the quarter.

 For purposes of determining value, securities and other instruments traded on a market for which actual
 transaction prices are publicly reported are valued at the last reported sale price on the principal market in which
 they are traded.

 When we provide investment management services, we do not charge additional fees to work with your
 attorney and/or accountant. Our fee includes the time and activities necessary to work with your attorney and/or
 accountant in reaching agreement on solutions, as well as assisting them in implementation of all appropriate
 documents. We are not responsible for attorney or accounting fees charged to you as a result of the above
 activities.

 Compensation for our services will be calculated in accordance with what is set in the client agreement.
 We may modify the terms of any agreement by written changes submitted to the client for signature.
 Changes will not be effective until Alchemi has received the signed agreement from the client. While we strive
 to maintain competitive fees, the same or similar services may be available from other firms at higher or lower
 fees.

 Alchemi requires written authorization from the client to deduct advisory fees from an account held by
 a qualified custodian. At the same time Alchemi sends the qualified custodian written notice of the amount of
 the fee to be deducted from the client’s account, Alchemi sends the client a written invoice itemizing the fee,
 including the formula used to calculate the fee, the time period covered by the fee and the amount of assets
 under management on which the fee was based. Alchemi fees are paid from your account by the custodian when
 we submit an invoice to them. We strongly urge you to compare our invoices to custodian statements for
 accuracy.

Alchemi Wealth, LLC
Form ADV Part 2 Brochure

 Alchemi’s investment management fees are generally calculated and payable quarterly in advance based on the
 value as of the last business day of the prior quarter, with payment due within 10 days from the date of the
 invoice. Some contracts charge in arrears, that is, at the end of the billing cycle as of the last day of the quarter.
 Our fee is determined by taking the percentage rate we charge, divided by four, times the market value of the
 account. The market value is the sum of the values of all assets in the account. In cases where there are partial
 periods at the commencement or termination of our agreement, fees will be billed or refunded on a pro‐rated
 basis based on the number of days services were provided in the quarter. Quarterly fee adjustments for additional
 assets received into the account during a quarter or for partial withdrawals will also be provided on the above
 pro rata basis.

 If there is insufficient cash in your account to pay your fees, securities in your portfolio may be sold to pay our
 fee. In addition to our fees, there may be custodial, mutual fund, 12b‐1 fees or similar third party
 management fees and charges.

 You are responsible for the payment of all third‐party fees (i.e. Custodian fees, mutual fund fees, 12b‐1
 fees, transaction fees & commissions, etc.). Those fees are also separate and distinct from the fees we charge.
 Alchemi does the best we can to minimize all fees and transaction costs by working with a Custodian that has low
 transaction costs and custodial fees, and has availability to low-cost ETFs and mutual funds.

 All brokerage commissions, stock transfer fees, 12b‐1 fees and other similar charges incurred in connection
 with transactions for the account will be paid out of the assets in the account and are in addition to the
 investment management fees paid to us. While we take measures to ensure the fees charged are accurate, it is
 your responsibility to ensure the amount of fee charged is correct. In addition to invoices and reports sent
 by us, you will receive statements directly from these custodians or mutual funds or other investments
 you hold. We strongly urge you to compare our invoices and reports to custodian statements for accuracy.

 The investment advisory contract may be terminated by the client within five (5) days of signing the contract
 without incurring any advisory fees or penalty. Ongoing, Alchemi or our clients can terminate our agreement
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Types of Clients - Item 7

 Alchemi generally provides asset management and financial planning services to Individuals, High‐Net‐Worth
 Individuals, Trusts, Estates, Corporations, and Charities. Alchemi does not have an account minimum.

                       Methods of Analysis, Investment Strategies and Risk of Loss - Item 8

 In determining the recommendations to give to you, we first gather and consider information regarding several
 factors including our client’s:

     •    Current financial situation;
     •    Investment goals and objectives;
     •    Current and long‐term needs;

Alchemi Wealth, LLC
Form ADV Part 2 Brochure

     •    Tolerance and appetite for risk; and
     •    Level of investment knowledge.

 Alchemi uses multiple sources of information to obtain analysis and strategies. They include sources such as
 financial newspapers, financial magazines, research prepared by others, corporate rating services, prospectuses,
 company press releases, annual reports and filings with the SEC.

 Alchemi’s methods of analysis include Charting analysis, Cyclical analysis, Fundamental analysis, Modern portfolio
 theory, Quantitative analysis and Technical analysis.

 Charting analysis involves the use of patterns in performance charts. Alchemi uses this technique to search for
 patterns used to help predict favorable conditions for buying and/or selling a security.

 Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a
 security.

 Fundamental analysis involves the analysis of financial statements, the general financial health of companies,
 and/or the analysis of management or competitive advantages.

 Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return
 for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by
 carefully choosing the proportions of various asset.

 Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such
 as the character of management or the state of employee morale, such as the value of assets, the cost of capital,
 historical projections of sales, and so on.

 Technical analysis involves the analysis of past market data; primarily price and volume.

 Investment Strategies
 Alchemi uses long term trading and short term trading.

 Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long‐term
 investment strategy can expose clients to various types of risk that will typically surface at various intervals during
 the time the client owns the investments. These risks include but are not limited to inflation (purchasing
 power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk.

 Short term trading risks include liquidity, economic stability, and inflation, in addition to the long term trading
 risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage
 and other transaction costs and taxes.

 Risk of Loss
 All investments include a risk of loss that clients should be prepared to bear. Performance of any investment is
 not guaranteed. We use our best efforts and expertise to manage your assets. However, we cannot guarantee
 any level of performance or that you will not experience financial loss.

 Charting analysis strategy involves using and comparing various charts to predict long and short term performance
 or market trends. The risk involved in using this method is that only past performance data is considered without
 using other methods to crosscheck data. Using charting analysis without other methods of analysis would be
 making the assumption that past performance will be indicative of future performance. This may not be the case.

Alchemi Wealth, LLC
Form ADV Part 2 Brochure

 Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to
 provide performance. The risks with this strategy are two‐ fold: 1) the markets do not always repeat cyclical
 patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these
 investors are trying to exploit.

 Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings.
 This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their
 perceived value. The risk assumed is that the market will fail to reach expectations of perceived value.

 Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the
 same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if
 compensated by higher expected returns. Conversely, an investor who wants higher expected returns must
 accept more risk. The exact trade‐off will be the same for all investors, but different investors will evaluate the
 trade‐off differently based on individual risk aversion characteristics. The implication is that a rational investor
 will not invest in a portfolio if a second portfolio exists with a more favorable risk‐expected return profile – i.e., if
 for that level of risk an alternative portfolio exists which has better expected returns.

 Quantitative analysis Investment strategies using quantitative models may perform differently than expected as
 a result of, among other things, the factors used in the models, the weight placed on each factor, changes from
 the factors’ historical trends, and technical issues in the construction and implementation of the models.

 Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption
 is that the market follows discernible patterns and if these patterns can be identified then a prediction can be
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