Arete Wealth Advisors LLC

Item 5 – Fees and Compensation

Depending upon the type of advisory service to be provided, Clients generally have a choice regarding the manner in which fees will be
calculated for such services. Fees can be billed either forward or in arrears. Options for calculating fees include the following:

ARETE WEALTH
FORM ADV PART 2A – DISCLOSURE BROCHURE                                                         (CON.)

   •    Percentage of assets under management;
   •    Hourly charges;
   •    Flat fees; or
   •    Some combination of the above.

  Generally speaking, fees are negotiable from Client to Client and are tailored to the specific types of services that Arete provides to that Client.

    A. Amount of Our Fees

 Calculation Based on Assets under Management:

This is the most common way Arete calculates fees. This is a calculation based on a percentage of assets managed for the Client. As noted above,
fees may be negotiated and are specific to the Client’s arrangement with Arete. Arete’s standard fee schedule for both individual and non-
individual Clients is the following:

  ASSETS UNDER MANAGEMENT                                                       MAXIMUM ANNUAL FEE
  $0* - $249,000                                                                3.00%
  $250,000 - $749,999                                                           2.50%
  $750,000 - $1,499,999                                                         2.00%
  $1,500,000 -$4,999,999                                                        1.75%
  $5,000,000 and over                                                           1.50%

*We generally require a $50,000 initial minimum account balance which may be waived based upon the individual needs and complexity of the
 particular Client situation. The final fee schedule will be attached to the IAC.

 Financial Planning

Arete Advisors can charge either an hourly fee or a flat fixed fee for Financial Planning services (as defined above). Hourly fees and fixed fees for
these services are negotiated between the Advisor and each Client. For example, payment may be at the conclusion of a specific service or project
or upon receipt of periodic invoicing (i.e. monthly or quarterly). The final fee structure will be disclosed in the IAC and/or Financial Planning
Agreement.

    B. Payment of Fees

By signing the IAC, Client directs the custodian to pay the advisory fee as instructed by Arete or any other third-party manager on a scheduled basis
without any additional prior notice to Client. By signing the Financial Planning Agreement, Client directs payment to be rendered to Arete from a
custodian, bank account, or via check as agreed upon by Arete Advisor and Client. All account assets, transactions, and advisory fees will be shown
on the monthly or quarterly statements provided by the custodian.

Arete does not have a refund policy. Client requests for refund of fees are handled on a case-by-case basis. The Client may terminate the account
within five (5) days written notice. There is no fee or penalty should the Client choose to terminate the account within five (5) days of account
opening.

 Solicitors Fee

ARETE WEALTH
FORM ADV PART 2A – DISCLOSURE BROCHURE                                                      (CON.)

Clients using a third-party money manager are assessed an advisory fee by the third-party money manager and are not assessed a fee by Arete.
This fee is generally set by the third-party money manager and not Arete but is fully disclosed by Arete prior to the Client’s agreement to utilize
such services. The fee charged by the third-party money manager is contained in the agreement for registered investment advisory services
between the Client and the third-party money manager and is in addition to any other fees charged by the third-party money manager and any
recommended investments. For example, the Client may be assessed: all fees, charges and commissions associated with a brokerage account
(which may be payable to Arete as the broker-dealer entering those transactions at the direction of the third- party money manager or the Client);
all fees and charges associated with the purchase or sale of mutual funds shares as disclosed in the prospectus (including, but not limited to, 12b-1
fees, contingent deferred sales charges and record keeping fees); custodian fees and any other fees deemed relevant; fees assessed by the
variable annuity company; or fees of any other third-party service Pursuant to the Solicitor’s Agreement that Arete has with these various third-
party money managers that it recommends to suitable Clients, Arete and its Advisor receive a fee (which is generally a percentage of the total
advisory fee paid to the third-party money manager by the Client) from the third- party money manager. This fee is fully disclosed to the Client
before entering into the investment advisory agreement with the third-party money manager and is contained in the solicitor disclosure document
provided to the Client. Moreover, the Client has to confirm with Arete the Client’s receipt of certain disclosures, which includes disclosure
regarding the fees of the third-party money manager.

Although Arete and its Advisors will recommend the services of a specific third-party money manager as suitable for the Client, it is possible that the
compensation received, directly or indirectly, by Arete and its Advisor for recommending a third-party money manager may be more than the
compensation Arete or its Advisor would receive if they recommended a different third-party money manager. Consequently, Arete and its Advisors
may have a financial incentive to recommend a particular third- party money manager over other programs or services that might meet the Client’s
needs at a lower cost (such as, mutual funds, ETFs, or fee plus commission arrangements). Similarly, Arete only recommends third-party money
...

Item 7 – Types of Clients

 Arete generally provides advisory services to:

   •    Individuals, including high net worth and ultra high net worth;
   •    Pension and Profit-Sharing Plans;
   •    Trusts, Estates and charitable organizations; and
   •    Other corporate and business entities.

 Account Requirements

 Generally, we require a $50,000 initial minimum account balance. We may waive the requirement based upon the Client’s needs and complexity
 of account. Arete’s investment management services may not be beneficial to non-accredited investors, as the relatively higher advisory fees and
 trading and transaction costs may have a negative impact on performance. See Item 5 of this Brochure for more information regarding advisory
 fees and the other fees and expenses Clients may pay in connection with our advisory services.

 General Note Regarding Managed Account Platforms and Wrap Programs

 Access to certain third-party money managers, platforms, and programs may be limited to certain types of accounts and may be subject to account minimums,
 which will vary and may be negotiable depending upon the third-party money managers, platforms, and programs selected. Such minimums will be
 disclosed through separate disclosure documents.

ARETE WEALTH
FORM ADV PART 2A – DISCLOSURE BROCHURE                                                        (CON.)