Bellwether Investment Group LLC

Item 5: Fees and Compensation

       A. Types of Advisory Services and Fees

  Investment Advisory Services

  Bellwether provides discretionary investment advisory services on a fee basis. Bellwether’s annual
  investment advisory fee shall vary from negotiable up to 2.00% of the total assets placed under
  Bellwether’s management/advisement. Bellwether does not adjust its advisory fee for intra-period
  additions or withdrawals of assets from managed accounts.

  Please Note: Fee Differentials. Bellwether shall generally price its advisory services based upon various
  objective and subjective factors. As a result, our clients could pay diverse fees based upon the type,
  amount and market value of their assets, the anticipated complexity of the engagement, the anticipated
  level and scope of the overall investment advisory and consulting services to be rendered. Additional
  factors effecting pricing can include related accounts, employee accounts, competition, and negotiations.
  Please Also Note: As a result of these objective and subjective factors, similarly situated clients could pay
  diverse fees, and the services to be provided by Bellwether to any particular client could be available from
  other advisers at lower fees. All clients and prospective clients should be guided accordingly.

  Bellwether's annual investment advisory fee shall include investment advisory services, and, to the extent
  requested by the client, financial planning and consulting services. In the event that the client requires
  extraordinary planning and/or consultation services (to be determined in the sole discretion of
  Bellwether), Bellwether may determine to charge for such additional services, the dollar amount of which
  shall be set forth in a separate written notice to the client.

  The Firm’s policy is to treat intra-quarter account additions and withdrawals equally (i.e., the Firm does
  not charge for intra-quarter additions or withdrawals) unless indicated to the contrary on the Firm’s
  Investment Advisory Agreement executed by the client

  Retirement Plan Consulting Services

  Bellwether provides pension consulting services pursuant to which it assists sponsors of self-directed
  retirement plans with monitoring of investment alternatives from which plan participants shall choose in
  self-directing the investments for their individual plan retirement accounts. Bellwether’s annual fee for
  these services shall generally range from negotiable up to 2.00% of the total assets maintained within the
  plan.

  Financial Planning and Consulting Services (Stand-Alone)

  Bellwether provides financial planning and/or consulting services (including investment and non-
  investment related matters, including estate planning, insurance planning, etc.) on a stand-alone fee basis.
  Bellwether’s planning and consulting fees are negotiable, but generally range from $1,000 to $15,000
  on a fixed fee basis, and from $75 to $400 on an hourly rate basis, depending upon the level and scope of
  the service(s) required and the professional(s) rendering the service(s). Generally, Bellwether requires that
  the client pay financial planning fees in arrears on completion of the service. In either case, services to be

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  provided, the applicable fee, and fee-paying arrangements are agreed upon in advance of services
  provided and are set forth in the executed financial planning agreement.

       B. Fee Deduction

  Clients may elect to have Bellwether’s advisory fees deducted from their custodial account. Both
  Bellwether's Investment Advisory Agreement and the custodial/ clearing agreement may authorize the
  custodian to debit the account for the amount of Bellwether's investment advisory fee and to directly
  remit that management fee to Bellwether in compliance with regulatory procedures.

       C. Custodial Fees

  As discussed below, unless the client directs otherwise or an individual client’s circumstances require,
  Bellwether shall generally recommend that RJA, an independent and unaffiliated SEC-registered broker-
  dealer and FINRA member, serve as the broker-dealer/custodian for client investment management
  assets. Broker-dealers such as RJA, generally do not, but may, charge brokerage commissions and/or
  transaction fees for effecting certain securities transactions. In addition to Bellwether’s investment
  management fee, clients will also incur, relative to all mutual fund and exchange traded fund purchases,
  internal charges imposed at the fund level (e.g. management fees and other fund expenses) and, under
  certain circumstances, broker-dealer charges.

  While certain custodians, including RJA, generally (with exceptions) do not currently charge fees on
  individual equity transactions (including ETFs), others do.

  There can be no assurance that RJA will not change its transaction fee pricing in the future. RJA may also
  assess fees to clients who elect to receive trade confirmations and account statements by regular mail
  rather than electronically.

       D. Fee Billing Process

  Bellwether shall generally deduct fees and/or bill clients quarterly in advance, based upon the market value of
  the client’s assets under management at the close of business on the last day of the previous quarter. In the
  instance that Bellwether has been engaged to provide Retirement Plan Consulting Services, Bellwether shall
  deduct fees and/or bill clients quarterly in arrears, based upon the market value of the Plan assets as of the
  last business day of the current quarter. The Investment Advisory Agreement between Bellwether and the
  client will continue in effect until terminated by either party by written notice in accordance with the terms of
  the Investment Advisory Agreement. Upon termination of any account, Bellwether shall refund on pro-rata
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Item 7: Types of Clients

  Bellwether’s clients generally include individuals, high net worth individuals, pension and profit-
  sharing plans, corporations, business entities, and charitable organizations. Bellwether does not have
  a minimum account size or advisory fee for investment supervisory services. Bellwether, at its sole
  discretion, may charge a lesser investment management fee or reduce or waive its minimum based
  upon certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets,
  dollar amount of assets to be managed, related accounts, account composition, competition, negotiations
  with client, etc.). In addition, certain Independent Manager(s) may impose varying minimum account
  values upon Bellwether’s clients.

  ANY QUESTIONS: Bellwether’s Chief Compliance Officer, John Lindsey, remains available to address
  any questions that a client or prospective client may have regarding advisory fees.