Binnacle Investments Inc

Item 5. Fees and Compensation
    A. Fee Schedule

    Portfolio Management Fees

    Wilon uses the value of the account as of the last business day of the billing period, after
    taking into account deposits and withdrawals, for purposes of determining the market
    value of the assets upon which the advisory fee is based.

    These fees are generally negotiable, and the final fee schedule will be memorialized in
    the client’s advisory agreement. Clients may terminate the agreement without penalty.

    Financial Planning Fees

    Fixed Fees
    The total financial planning fee is based on the scope and complexity of the client’s
    situation. The flat fee charged is from $2,500 up to $15,000.

2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com

    Hourly Fees
    Each client’s fee for service is different and is based on the specific needs and factors
    involved. The fee for these services is based on an hourly rate determined by the nature
    and complexity of the services requested. The negotiated hourly fee for these services is
    between $150 and $350.

    Clients may terminate the agreement without penalty, for full refund of Wilon’s fees, within
    five business days of signing the Financial Planning Agreement. Thereafter, clients may
    terminate the Financial Planning Agreement generally upon written notice.

    Other Additional Fees

    Advisory Fees in General: Clients should note that similar advisory services may (or may not) be
    available from other registered (or unregistered) investment advisers for similar or lower fees.

    Mutual Fund Fees: Mutual funds often offer multiple share classes with differing internal fee and
    expense structures. Wilon endeavors to identify and utilize the share class with the lowest internal
    fee and expense structure for each mutual fund. However, instances occur in which the lowest cost
    share class is not used. These instances include but are not limited to: Instances in which a certain
    custodian has a share class available that has a lower internal fee and expense structure than is
    available for the same mutual fund at other custodians. In such instances, Wilon will select the lowest
    cost share class available at the custodian that holds your account even though a lower cost share
    class is available at another custodian. Instances in which the custodian that holds your account
    offers others a share class with a lower internal fee and expense structure than what is available to
    Wilon at the same custodian. In such instances, Wilon will select the lowest cost share class that the
    custodian makes available. This situation sometimes occurs because the custodian places
    conditions on the availability of the lower cost share class that Wilon has determined are not
    appropriate to accept due to additional costs imposed by said conditions. Instances in which a share
    class with a lower internal fee and expense structure becomes available after the share class you
    hold was purchased. Wilon periodically monitors this circumstance. However, a share class with a
    lower internal fee may become available between the time of your purchase and Wilon’s next review.
    Instances in which a share class with a lower internal fee and expense structure than the share class
    you currently hold is available at your custodian, but where Wilon is prevented by either the
    custodian or the fund sponsor from converting to the lower cost share class. Additionally, Wilon does
    not convert to a share class with a lower internal fee and expense structure if the conversion will
    cause a taxable event or other expense/cost to you that negates the advantage of the lower cost
    share class.

2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com

    Non-Transaction Fee (NTF) Mutual Funds: When selecting investments for our clients’ portfolios
    we might choose mutual funds on your account custodian’s Non-Transaction Fee (NTF) list. This
    means that your account custodian will not charge a transaction fee or commission associated with
    the purchase or sale of the mutual fund. The mutual fund companies that choose to participate in
    your custodian’s NTF fund program pay a fee to be included in the NTF program. The fee that a
    mutual fund company pays to participate in the program is ultimately borne by the owners of the
    mutual fund including clients of our Firm. When we decide whether to choose a fund from your
    custodian’s NTF list or not, we consider our expected holding period of the fund, the position size
    and the expense ratio of the fund versus alternative funds. Depending on our analysis and future
    events, NTF funds might not always be in your best interest.

    Unmanaged Assets: From time to time, a Client may decide to hold certain securities or other
    property for which our Firm does not provide investment advisory services ("Unmanaged Assets") in
    the account(s) held at the Custodian or outside the Custodian. Unmanaged assets will be shown on
    Wilon reports as unmanaged assets. It is the client’s sole responsibility to verify the accuracy of the
    Unmanaged status of any and all investments in their accounts and to notify Wilon in writing of any
    corrections or adjustments that need to be made. Our Firm will have no duty, responsibility or liability
    whatsoever with respect to these assets, and therefore, our Firm will not charge an investment
    advisory fee. However, if you have an account that solely contains Unmanaged Assets, the
    Custodian may charge an account maintenance fee as disclosed in the Custodian account
    paperwork executed by the Client. In all cases, it is the clients sole responsibility to monitor,
    manage, and transact all Unmanaged Assets (securities and/or accounts).
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Item 7. Types of Clients
    Wilon generally provides services, which may include financial planning and asset
    management, to individuals, high-net-worth individuals, trusts, estates, charitable
    organizations and business entities.

    Wilon generally requires clients to have a minimum of $250,000 in investable assets. This
    threshold has been established to allow Wilon to provide a high level of personal service
    and attention which we believe our clients deserve.

2400 86th Street, Sui te 32, U rbandal e, IA 50322 | 515- 225- 9500 | www .wilonw m.com