Beacon Capital Management Inc

Item 5: Fees and Compensation

Beacon’s fees vary depending on factors including, but not limited to, the type of service provided,
invested strategy, and product type.

                                                                                               Rev. 8/2025

                                                                      Beacon Capital Management, Inc.
                                                                                         ADV Part 2A

A. Advisory Fees

Beacon charges a management fee for our various investment advisory services, as detailed in the below
sections.

       1. Direct Accounts and Custom Portfolio Solutions

       For our investment advisory services, we charge the below fees for Direct Accounts:

                Average Daily Value of Client Account        Annual Fee %

                $0-$499,999.99                               0.55%

                $500,000-$999,999.99                         0.35%

                $1,000,000+                                  0.15%

                Minimum Annual Fee Charge                    $400.00*

       *Average Daily Values of Client accounts under $72,728 will be charged more than 0.55%
       annually because of the $400.00 minimum annual fee. Note that the $72,728 figure reflects the
       account value at which the $400 annual minimum equals 0.55%; it is not Beacon’s account-
       opening minimum, which is $25,000 (see Item 7).

       Direct account advisory fees are negotiable between Beacon and the custodian, Platform
       Provider, or Retail Advisor. Custom Portfolio Solutions also adhere to this fee schedule.

       Astor Accounts. Beacon has acquired Client accounts from Astor. As part of this transition, some
       legacy Astor Clients may continue to be billed under fee schedules that differ from Beacon’s
       current standard fee structure. Beacon has chosen to honor the historical fee arrangements in
       place at the time of acquisition. As a result, these Clients may pay higher or lower fees than
       those charged to new Clients under Beacon’s prevailing advisory agreements. Astor accounts
       will be billed monthly or quarterly according to the agreements with the Clients and platforms.

       Unsupervised Assets. From time to time, Clients may hold securities which are not part of
       Beacon’s model portfolios. Although these assets can be held in an account managed by Beacon,
       they will not be actively managed by Beacon. Beacon reserves the right to assess an
       administrative fee of 0.10% for assets in this classification.

       2. Model Delivery Advisory Services

       Fees for model delivery advisory services are negotiated with the Platform Provider and will
       range from 0.20% to 0.60% per year.

                                                                                             Rev. 8/2025

                                                                         Beacon Capital Management, Inc.
                                                                                            ADV Part 2A

        3. Investment Supervisory Services

        Fees for supervisory services are negotiated on a Client-by-Client basis and will follow the direct
        account fee schedule listed above. The overall fee - including any Retail Advisor fee - will be the
        greater of 1.8% annually or $400 minimum per year. Fees for supervisory services are
        negotiated on a Client-by-Client basis. All Investment Supervisory fees are disclosed and
        documented via your investment management agreement with us.

B. ERISA Account Considerations

Accounts subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), (each
a “Plan”) should note that Beacon’s direct compensation is comprised of the management fee described
above and the administrative fee (if applicable). Beacon’s management fee will be deducted from Plan
assets unless otherwise dictated by written agreement between Beacon and the Plan. Beacon does not
receive any additional direct compensation.

Beacon’s indirect compensation consists of gifts and entertainment received from vendors and plan
fiduciaries in the normal course of business. Beacon’s employees are required to report the receipt of
such gifts and entertainment. The amount of these is expected to be de minimis and fall below the
Department of Labor’s reporting requirements. Additionally, the receipt of these items is not tied to
Beacon’s performance or services related to the Plan.

Beacon does not receive any additional indirect compensation.

Please visit www.beaconinvesting.com/disclaimers for a detailed disclosure as required by ERISA Section
408(b)(2).

C. Payment of Fees

Advisory fees for Direct Accounts, model delivery advisory services, and supervisory services are
generally withdrawn directly from the Client’s account. Fees are due either monthly or quarterly and
either in advance or in arrears, as directed by the individual contract with each Client or the contract
with the Platform Provider or custodian. Depending on the arrangement, Beacon or the Platform
Provider or custodian will calculate the fees.

In non-Beacon sponsored Wrap Fee Programs, the Sponsor will bill Clients for the full wrap fee then
remit a portion of the fee to Beacon for our management.

In certain circumstances and depending on the specific contract in place, Beacon may bill direct account
Clients and investment supervisory services Clients directly for Beacon’s fees.

D. Other Fees and Expenses
In addition to Beacon’s management fee, Clients may incur certain charges imposed by unaffiliated third
parties in connection with the maintenance of and activity in the Account, including: custodial fees, non-
commission/transaction-based administrative fees, fees imposed directly by an investment company,
...

Item 7: Types of Clients

Beacon generally provides investment advisory services to the following types of Clients:

    •   High-Net-Worth Individuals
    •   Individuals
    •   Pension and Profit-Sharing Plans
    •   Corporations or Business Entities
    •   Registered Investment Companies
    •   Trusts
    •   Estates
    •   Charitable Organizations

Beacon’s strategies generally require a $25,000 account minimum. The minimum requirement is
negotiable at Beacon’s discretion. Beacon can group certain related Client accounts for the purposes of
achieving the minimum account size. Account minimums for certain Wrap Fee Programs and model
delivery platforms may be higher.