ATON Advisors LLC

Item 5 – Fees and Compensation
  Description of Fees
     Depending on the type of service provided, ATON Advisors bases its fees on a percentage
     of assets under management, hourly charges, and fixed fees. More detailed information
     regarding the fees for each type of agreement are outlined in the Types of Agreements
     section above.
     Advisory Service Agreements are typically billed based on a percentage of assets under
     management. Some Retainer Agreements may be priced based on the complexity of
     work, especially when asset management is not the most significant part of the
     relationship. Financial plans are priced according to the degree of complexity associated
     with the client’s situation.
     Fees are negotiable. ATON Advisors, in its sole discretion, may waive its minimum fee
     and/or charge a lesser investment advisory fee based upon certain criteria (e.g., historical
     relationship, type of assets, anticipated future earning capacity, anticipated future
     additional assets, dollar amounts of assets to be managed, related accounts, account
     composition, negotiations with clients, etc.).
     Please note, unless you have received our Firm Brochure at least 48 hours prior to signing
     an advisory agreement, you can terminate the agreement within five business days of
     signing the agreement without incurring any penalties and advisory fees.

  Fee Billing
     Fees for Advisory Service and Retainer Agreements are billed quarterly in advance,
     meaning that we invoice you before the three-month billing period has begun. Payment in
     full is expected upon invoice presentation. Fees are usually deducted from a designated

                                           ATON Advisors

     client account to facilitate billing. The client must consent in advance to direct debiting of
     their investment account.
     Fees for Financial Planning Agreements are billed 100% in advance.
     Fees for Hourly Engagements are paid in arrears.

  Other Fees and Expense
     Our fees are exclusive of brokerage commissions, transaction fees, and other related
     costs and expenses. You could incur certain charges imposed by custodians, brokers,
     and other third-parties, such as custodial fees, deferred sales charges, transfer taxes, wire
     transfer and electronic fund fees, and other fees and taxes on brokerage accounts and
     securities transactions. Such charges, fees, and commissions are exclusive of and in
     addition to our fee, and we do not receive any portion of these commissions, fees, and
     costs.
     Custodians may charge transaction fees on purchases or sales of certain mutual funds
     and exchange-traded funds. These transaction charges are usually small and incidental
     to the purchase or sale of a security. The selection of the security is more important than
     the nominal fee that the custodian charges to buy or sell the security.
     Mutual funds generally charge a management fee for their services as investment
     managers. The management fee is called an expense ratio. For example, an expense
     ratio of 0.50 means that the mutual fund company charges 0.5% for their services.
     Performance figures quoted by mutual fund companies in various publications are after
     their fees have been deducted.

  Termination of Agreements and Past Due Accounts
     A client may terminate any agreement at any time by notifying ATON Advisors in writing
     and paying the rate for the time spent on the investment advisory engagement prior to
     notification of termination. If the client made an advance payment, ATON Advisors will
     refund any unearned portion of the advance payment.
     ATON Advisors may also terminate any agreement at any time by notifying the client in
     writing. ATON Advisors reserves the right to stop work on any account that is more than
     15 days overdue. In addition, ATON Advisors reserves the right to terminate any
     agreement where a client has willfully concealed or has refused to provide pertinent
     information about financial situations when necessary and appropriate, in ATON Advisors’
     judgment, to providing proper financial advice. Any unused portion of fees collected in
     advance will be refunded within 15 days.

Item 7 – Types of Clients
  Description
     ATON Advisors generally provides investment management and financial planning
     services to individuals, pension and profit-sharing plans, trusts, estates, charitable
     organizations, corporations, or other business entities. Client relationships vary in scope
     and length of service.

  Account Minimums
     There is not a minimum account size to receive our services. However, for our Advisory
     Service Agreements, there are different account service levels based on the amount of
     assets under management, as described in the Types of Agreements section above.
     ATON Advisors has the discretion to waive the account minimum for any service level.