Atlas Brown Inc

Item 5 – Fees and Compensation
Investment Management Services (Discretionary and Non-Discretionary)
With respect to its investment management and advisory services, Atlas Brown charges its clients
an annualized fee based upon a percentage of the market value of the clients' assets being managed
by Atlas Brown. Atlas Brown’s annualized fee is as follows:

       PORTFOLIO VALUE                 ANNUAL FEE
       First $1,000,000                2.00%
       Next $4,000,000                 1.00%
       Next $5,000,000                 0.75%
       Next $15,000,000                0.60%
       On the balance                  0.50%

The typical annualized fee is between 0.75% and 1.00% (may include breakpoints) depending upon
the market value of the assets under management, the type of investment management services to
be rendered, and the Family Office Services required by each client.

Atlas Brown’s annualized fee is exclusive of, and in addition to, any separate brokerage
commissions, transaction fees, separate account manager fees, and/or other related costs and
expenses which may be incurred by the client (see Item 12-Brokerage Practices). The annualized
fee is charged quarterly, in advance, based upon the market value of the assets on the last business
day of the previous quarter. Assets are typically valued by the independent custodian or another
independent third party. If values are not available from either of such sources, they are initially
valued at cost by Atlas Brown’s Valuation Committee. The Valuation Committee will meet quarterly
to review all pricing documentation and determine if any price adjustment is warranted based on
any financing or monetization event. The first quarter’s fees shall be based on the month end
market value of the assets subsequent to the receipt of the assets and shall be calculated on a pro
rata basis (e.g., based on the number of days remaining in such calendar quarter). If additional
assets are deposited into an account after the inception of a quarter, the fee payable to Atlas Brown
with respect to such assets will be prorated based on the number of days remaining in the quarter.

The custodian for client accounts typically directly debits each client’s account for the amount of
the quarterly fee and forward such amount directly to Atlas Brown, as long as any such custodian
sends a statement to the client, at least quarterly, indicating:

           a) all amounts disbursed from the account (including the amount of management fees
              paid directly to Atlas Brown);
           b) the amount of funds and securities in the account at the end of the period; and
           c) all transactions in the account during that period.

In addition, the management fee is subject to negotiation. Atlas Brown may charge a lesser
investment management fee in certain circumstances (e.g., discounted fees for employees), and will
base any such decisions on the factors that it deems appropriate, including, without limitation,
anticipated future earning capacity, anticipated future additional assets, the dollar amount of assets
to be managed, related accounts, account composition, pre-existing client status, and continued
account retention.

Any agreement between Atlas Brown and the client will continue in effect until terminated by
either party pursuant to the terms of such agreement. Clients who terminate their relationship with
Atlas Brown within ten (10) calendar days of signing an agreement for investment management
services and/or Family Office Services will receive a prompt refund of all monies paid by the client
to Atlas Brown. If clients terminate their relationship with Atlas Brown after the initial ten-day
period, Atlas Brown’s fee shall be prorated through the date of termination and any remaining
balance shall be charged or refunded to the client, as applicable, in a timely manner.

With respect to withdrawals exceeding $1 million from an account within a calendar quarter, Atlas
Brown shall credit its unearned fee towards the next quarter’s fee or refund the fee to the client as
so instructed by the client. Atlas Brown designs its portfolios as long-term investments and clients
should be aware that asset withdrawals may impair the achievement of a client’s investment
objectives.

On an extremely limited basis, when providing investment management consulting services and/or
Family Office Services, Atlas Brown will charge these clients an annual flat fee (charged quarterly)
as agreed upon in writing by Atlas Brown and the client.

Other Fees and Expenses
In addition to the fees paid to Atlas Brown for investment advisory services, a client may incur a
separate fee imposed by the qualified custodian and/or broker-dealer. These fees may be asset-
based fees or transaction-based fees such as commissions on trades occurring in the account. In
any case, a client’s custodian or broker-dealer is independent of Atlas Brown and may revise its fees
at any time.

When securities are purchased or sold by Atlas Brown on behalf of a client, the client will also incur
brokerage and possibly other transaction costs (see Item 12 Brokerage Practices). If an account
holds mutual funds or exchange-traded funds, the funds’ investment management fees and other
expenses are typically deducted automatically and paid to the funds’ management companies in
accordance with the methodology outlined in the prospectus issued for each fund. Separate
account managers are also deducted automatically and paid to the manager as provided in the
Separate Account Manager Addendum. These fees are in addition to the investment management
fees paid to Atlas Brown. Atlas Brown receives no additional compensation or service fees from the
mutual funds or exchange traded funds that may be held in a client’s account nor any separate
account manager fees. Clients who invest in private investments will incur multiple layers of fees
...

Item 7 – Types of Clients
Atlas Brown does not require any specific minimum initial investment. Atlas Brown currently
provides investment management services to the following types of clients:

   •   Individuals and their families (including high net worth individuals);
   •   Retirement Plans (401k, Profit-Sharing, Cash Balance and Pension Plans);
   •   Trusts, Estates, or Charitable Organizations; and
   •   Corporations.