Benchmark Capital Group Ltd

Item 5 Fees and Compensation
Please refer to the “Advisory Business” section in this brochure for information on our advisory fees,
fee deduction arrangements, and refund policy according to each service we offer.

Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in
mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds or exchange
traded funds (described in each fund’s prospectus) to their shareholders. These fees will generally
include a management fee and other fund expenses. You will also incur transaction charges and/or
brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by
the broker-dealer or custodian through whom your account transactions are executed. We do not
share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or
custodian. To fully understand the total cost you will incur, you should review all the fees charged by
mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices,
please refer to the “Brokerage Practices” section of this brochure.

We may trade your accounts on margin. You must sign a separate margin agreement before margin is
extended to your account. Fees for advice and execution on these securities are based on the total
asset value of the account, which includes the value of the securities purchased on margin. While a
negative amount may show on your statement for the margined security as the result of a lower net
market value, the amount of the fee is based on the absolute market value. This could create a conflict
of interest where we have an incentive to encourage the use of margin to create a higher market value
and therefore receive a higher fee. The use of margin may also result in interest charges in addition to
all other fees and expenses associated with the security involved.

IRA Rollover Considerations
As part of our investment advisory services to you, we may recommend that you withdraw the assets
from your employer's retirement plan and roll the assets over to an individual retirement account
("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our
management, we will charge you an asset based fee as set forth in the agreement you executed with
our firm. This practice presents a conflict of interest because persons providing investment advice on
our behalf have an incentive to recommend a rollover to you for the purpose of generating fee based

compensation rather than solely based on your needs. You are under no obligation, contractually or
otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no
obligation to have the assets in an IRA managed by our firm.

Many employers permit former employees to keep their retirement assets in their company plan. Also,
current employees can sometimes move assets out of their company plan before they retire or change
jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options
are available, you should consider the costs and benefits of:

An employee will typically have four options:
    1. Leaving the funds in your employer's (former employer's) plan.
    2. Moving the funds to a new employer’s retirement plan.
    3. Cashing out and taking a taxable distribution from the plan.
    4. Rolling the funds into an IRA rollover account.
Each of these options has advantages and disadvantages and before making a change we encourage
you to speak with your CPA and/or tax attorney.

If you are considering rolling over your retirement funds to an IRA for us to manage here are a few
points to consider before you do so:
     1. Determine whether the investment options in your employer's retirement plan address your
        needs or whether you might want to consider other types of investments.
             a. Employer retirement plans generally have a more limited investment menu than IRAs.
             b. Employer retirement plans may have unique investment options not available to the
                public such as employer securities, or previously closed funds.
     2. Your current plan may have lower fees than our fees.
             a. If you are interested in investing only in mutual funds, you should understand the cost
                structure of the share classes available in your employer's retirement plan and how the
                costs of those share classes compare with those available in an IRA.
             b. You should understand the various products and services you might take advantage of
                at an IRA provider and the potential costs of those products and services.
     3. Our strategy may have higher or lower risks than the option(s) provided to you in your plan.
     4. Your current plan may also offer financial advice.
     5. If you keep your assets titled in a 401k or retirement account, you could potentially delay your
        required minimum distribution beyond age 72.
     6. Your 401k may offer more liability protection than a rollover IRA; each state may vary.
             a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA
                assets have been generally protected from creditors in bankruptcies. However, there
                can be some exceptions to the general rules so you should consult with an attorney if
                you are concerned about protecting your retirement plan assets from creditors.
     7. You may be able to take out a loan on your 401k, but not from an IRA.
     8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax
...

Item 7 Types of Clients
We offer investment advisory services to individuals, trusts, estates, charitable organizations,
corporations, and other business entities.

In general, we require a minimum of $150,000 to open and maintain an advisory account. At our
discretion, we may waive this minimum account size. For example, we may waive the minimum if you
appear to have significant potential for increasing your assets under our management. We may also
combine account values for you and your minor children, joint accounts with your spouse, and other
types of related accounts to meet the stated minimum.