Beirne Wealth Consulting Services LLC

Item 5. Fees and Compensation

Except as described in Item 14, there are no referral fees received by BWC for
recommending the services of other professionals, such as estate or tax professionals.
From time to time, BWC may pay its employees additional internal cash compensation,
in addition to their regular salary, for referring new advisory clients to the Firm. This
compensation is paid by BWC and does not increase the advisory fees paid by clients
The Firm offers its services on a fee basis, which includes fixed fees, fees based upon
assets under management, or a combination of both. BWC employees receive cash
compensation in addition to employee’s regular salary in exchange for client referrals

Investment Management Fees
BWC manages assets on a wrapped and unwrapped basis. The Firm provides
investment management services for an annual fee based upon a percentage of the
market value of the assets being managed by BWC pursuant to a tiered fee schedule.

For services provided outside of the Wrap Program, BWC’s annual fee is exclusive of,
and in addition to brokerage commissions, transaction fees, and other related costs and
expenses, which are incurred by the client. BWC does not, however, receive any portion
of these commissions, fees, and costs.

BWC’s annual fee is prorated and charged quarterly, in advance, based upon the market
value of the assets being managed by BWC on the last day of the previous quarter. The
annual fee shall be negotiated and will vary depending upon a number of factors, including
the market value of the assets under management, the type of investment management
services to be rendered, type of products being managed, anticipated amount of
resources utilized in the relationship, anticipated future additional assets, and the
existence of related accounts.

As discussed above, BWC no longer offers the Program to new clients. New clients may
only engage BWC to provide investment management services outside of the Program.
BWC provides investment management services to individual and high net worth clients
according to the following tiered fee schedule, subject to negotiation:

                             PORTFOLIO VALUE        ANNUAL FEE

                                 First $1,000,000      1.25%
                                 Next $2,000,000       1.20%

                                 Next $2,000,000       1.15%

                                 Next $5,000,000       1.10%

                               Above $10,000,000       1.00%

When BWC provides investment management services to institutional clients, advisory
fees are structured on a case-by-case basis. Fees are charged based on assets under
management and/or advisory services, as a flat fee, or as a combination of a flat fee plus
an asset-based fee. The highest asset-based fee charged to institutional clients is up to
100 basis points or 1%.

The asset-based management fee(s) is prorated and billed quarterly in advance, based
on the market value of the assets being managed by BWC on the last day of the previous
quarter.

Custodians, Independent Managers and the platform manager charge their own fees that

are in addition to BWC’s fees.

Fees Charged by Independent Managers and Financial Institutions

As further discussed in response to Item 12 (below), BWC generally recommends that
clients utilize the brokerage and clearing services of Fidelity Institutional Wealth Services
(“Fidelity”) for investment management accounts.

The Firm only implements its investment management recommendations after the client
has arranged for and furnished BWC with all information and authorization regarding
accounts with appropriate financial institutions. Financial institutions include, but are not
limited to, Fidelity, any other broker-dealer recommended by BWC, broker-dealer
directed by the client, trust companies, banks, etc. (collectively referred to herein as the
“Financial Institutions”).

Clients incur certain charges imposed by the Financial Institutions and other third parties such as
fees charged by Independent Managers (as defined below), custodial fees, charges
imposed directly by a mutual fund or ETF in the account, which are disclosed in the fund’s
prospectus (e.g., fund management fees and other fund expenses), deferred sales
charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and
other fees and taxes on brokerage accounts and securities transactions. Additionally, for
assets outside of any wrap fee programs, clients incur brokerage commissions and
transaction fees. Such charges, fees and commissions are exclusive of and in addition
to BWC’s fee.

BWC’s Agreement and the separate agreement with any Financial Institutions authorize
BWC or Independent Managers to debit the client’s account for the amount of BWC’s
fee and to directly remit that management fee to BWC or the Independent Managers.
Any Financial Institutions recommended by BWC have agreed to send a statement to
the client, at least quarterly, indicating all amounts disbursed from the account including
the amount of management fees paid directly to BWC. We urge you to review these
statements carefully. In certain circumstances, BWC’s fees, Independent Manager fees,
custodial fees and other fees will be directly invoiced to the client for payment.

Platform Fee

BWC utilizes third‑party platform service providers to support portfolio reporting, billing,
and related back‑office functions. Historically, these services were provided through

Envestnet, Inc. Effective February 9, 2026, BWC engaged Orion Advisor Technology,
LLC (“Orion”) as a third‑party technology and reporting service provider and began
transitioning these services from Envestnet, Inc.
Orion does not have discretionary authority over client accounts and does not act as a
qualified custodian. BWC does not expect this transition to result in any material change
to clients’ investment management services or advisory fees.
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Item 7. Types of Clients
BWC provides its services to institutions, high net worth individuals, profit sharing plans,
trusts, estates, charitable organizations, corporations, government, quasi-government,
foundations, endowments and business entities.
Minimums
The Firm generally does not implement account minimums but imposes a minimum fee
in limited circumstances for certain legacy. Additionally, certain Independent Managers
impose more restrictive account requirements and varying billing practices than BWC. In
such instances, BWC alters its corresponding account requirements and/or billing
practices to accommodate those of the Independent Managers.