Ballast Capital Advisors LLC

ITEM 5 – FEES AND COMPENSATION
         Clients are in need of two skill sets – financial planning and investment management. Both of
these are activities are for the most part fixed in cost. Larger accounts require more attention due to
tax, estate and some incremental investment opportunities – however, clearly the activity doesn’t
increase 1 for 1 with your assets.
         We bill for our fees quarterly and they are payable in advance. Our minimum account size and
fees are negotiable in certain circumstances. Fees can be paid by having them deducted directly from
your account or by check. The choice is yours.

Our annual fee schedule is the following:

        Asset Size:                                The greater of 0.75% of AUM
                                                   or the fixed fee listed below:
        <300,000                                   $4,500
        300,001 -     $600,000                     $5,500
        $600,001 -    $900,000                     $7,500
        $900,001 - $1,500,000                      $10,000
        $1,500,001 - $3,000,000                    $17,500
        $3,000,001 - $5,500,000                    $30,000
        $5,500,001 - $10,000,000                   $50,000
        $10,000,001+                               Negotiable

        This fee is billed quarterly in advance.

         To construct your portfolio, we may employ the use of ETFs or possibly mutual funds. If we do,
you will incur mutual fund fees and expenses that are in addition to the fees we charge you. Mutual
funds pass these fees and expenses on to investors directly - they are not charged nor billed by us.
         We primarily use RBC (“Custodian”) a registered broker-dealer and member of the Securities
Investor Protection Corporation, as our custodian. Through our use of Custodian’s services, you will
incur a Custodian in addition to our fees. These costs are further explained below in Item 12.
         Financial, Retirement, Estate, and Tax Planning services are included with the flat fee for
investment management previously discussed. There is no additional fee for any of these services;
however, these services are only provided to investment management clients.

Additional Fee Information
         Clients may authorize us to directly debit management fees from client accounts on a quarterly
basis. In such instances, management fees are pro-rated for each capital contribution and withdrawal
made during the applicable calendar quarter. Accounts initiated or terminated during a calendar period
will be charged a pro-rated fee. Upon termination, any unearned fees will be refunded to you.
Alternatively, in some instances, clients may receive an invoice for fees, in which the client may choose
to pay us directly for our billed fees for the relevant period. Our fees are exclusive of brokerage
commissions, transaction fees, and other related costs and expenses which shall be incurred directly by
the client. Clients may incur certain charges imposed by custodians, brokers, and other third parties
such as fees charged by third party managers, fund managers, custodial fees, deferred sales charges,
odd-lot differentials, transfer taxes, wire transfer and electronic funds fees, and other fees and taxes on
brokerage account and securities transactions. Mutual funds and exchange-traded funds also charge
internal management fees, which are disclosed in a fund’s prospectus.
         Trades are typically reviewed and reconciled the next business day after trades are placed.
Occasionally, the Firm may make an error in submitting a trade order on your behalf. When this occurs,
Advisor may place a correcting trade with the broker-dealer which has custody of your account. If an
investment gain results from the correcting trade, the gain will remain in your account unless the same
error involved other client account(s) that should have received the gain, it is not permissible for you to
retain the gain, or we confer with you and you decide to forego the gain (e.g., due to tax reasons). If a
loss occurs, the Firm will pay for the loss. Generally, if related trade errors result in both gains and
losses in your account, they may be netted. The Firm maintains a trade error folder that includes the
documentation and resolution of the trade error.

ITEM 7 – TYPES OF CLIENTS
         We provide investment advice to individuals, funds, retirement plans, trusts, estates, charitable
 organizations, corporations and other business entities.