ATON Financial LLC

Item 5 Fees and Compensation

Asset Management Fees
Pursuant to an investment advisory contract signed by each client, the client will pay ATON a
blended annual management fee, payable quarterly in arrears, based on the value of portfolio assets
of the account on the last business day of the preceding quarter. The fee is adjusted for any deposits
or withdrawals during the quarter. For example, the fee on assets withdrawn will be calculated
from the beginning of the quarter to the date of the withdrawal and added to the fee calculated on
the quarter-end assets, and the fee for deposits will be calculated from the beginning of the quarter
to the deposit date and deducted from the fee calculated on quarter-end assets. New account fees
will be prorated from the inception of the account to the end of the first quarter. The management
fee is negotiable at the discretion of the Advisor.

         Assets Under Management                 Annual Fee
         Up to $100,000                             1.50%
         $100,001 to $250,000                       1.40%
         $250,001 to $500,000                       1.30%
         $500,001 to $1,000,000                     1.15%
         $1,000,001 to $3,000,000                   1.00%
         Over $3,000,000                            0.75%

For example, an account $500,000 will pay an annual fee of $6,850 calculated as 1.50% on the
first $100,000, plus 1.40% on the next $150,000, plus 1.30% on the remaining $250,000.

ATON’s minimum fee is $1,500 per year. However, ATON’s fee will never exceed 2.00% of the
assets being managed for the client.

These fees may be negotiated at the Advisor’s discretion. When possible, the asset management
fees will be directly deducted from the client account on a quarterly basis by the qualified
custodian. The client will give written authorization permitting the Advisor to be paid directly
from their account held by the custodian. The custodian will send a quarterly statement to the

client showing all transactions in the account, including the asset management fee amount
withdrawn from the client account. For accounts where direct fee deduction is not possible, Client
will be sent an invoice on a quarterly basis for any outstanding advisory fees due.

Fixed Fees
Some investment advisory clients may choose to pay for investment consulting services or
financial planning services on an annual retainer of up to $15,000 per year. Such fixed fee
arrangements are negotiable at the discretion of the Advisor, and will be billed to clients either
quarterly in arrears or quarterly in advance.

For financial planning clients, ATON may charge a fixed fee of $500 per month for ongoing
financial planning services as contracted for with client in advance. Fixed fees may be negotiated
in advance based at the discretion of the Advisor. Fixed fee-based financial planning clients are
billed on a monthly basis upon completion of work performed.

Alternatively, clients may choose to have ATON provide comprehensive financial planning for a
one-time fixed fee of $5,000, which will be negotiated at the Advisor’s discretion and agreed with
the client in writing. The services included in the financial planning include:
    • IPS development
    • Recommendation of an asset allocation and portfolio construction based on the IPS and
        capital market expectations
    • Analysis of client’s current portfolio including
             o Allocation
             o Holdings
             o Fees
    • Comparison of current portfolio vs. proposed
    • Provide recommendations for implementation considering factors such as
             o Fees
             o Active vs. passive investment vehicle analysis to achieve investment objectives

Clients choosing the one-time fee option for comprehensive financial planning will be charged the
fee in advance or in arrears as negotiated with the client. If the fee is charged in advance, the work
will be completed and delivered to the client in less than six months from the date of the agreement.
If the agreement is terminated prior to completion of the comprehensive financial plan and the fee
was paid in advance, the fee paid in advance will be prorated to the date of termination and any
excess will be refunded to client. If the fee was agreed to be paid in arrears, Advisor will calculate
the fees due when the agreement is terminated and invoice the client. Payment is due within five
days of the delivery of the invoice.

Hourly Fees
Some clients will contract to have investment advisory or financial planning advice provided based
on an hourly fee rather than based on a percentage of assets under management. The Advisors
hourly fee will be billed at a rate of $250 per hour. The Advisors hourly fees will be negotiated
and agreed upon by the parties in advance. Hourly fee-based clients are billed on a monthly basis
upon completion of work performed.

Other
The Firm utilizes a third-party payment processing service to facilitate the collection of advisory
fees. Clients may pay fees through electronic funds transfer (ACH) or credit card, where available.
Any applicable processing or transaction fees will be disclosed to clients prior to payment.

For each of the Advisor's services described above, the Client may terminate these services within
five business days of the effective date of an Agreement signed with the Advisor without any
payment of the Advisor's fee.

All fees paid to ATON for investment advisory services are separate and distinct from the expenses
charged by mutual funds to their shareholders and the product sponsor in the case of variable
insurance products. These fees and expenses are described in each fund’s or variable product’s
prospectus. These fees will generally include a management fee and other fund expenses.

At no time will ATON accept or maintain custody of a client’s funds or securities except for
...

Item 7 Types of Clients

The Advisor will offer its services to individuals, trusts, estates, charitable organizations,
retirement plans, private funds, corporations and other business entities.

The Advisor does not have any minimum requirements for opening or maintaining an account.