Blacktower Financial Management US LLC

Item 5: Fees and Compensation
Your Advisory Representative has a direct interest in the fee charged to you since we will
pay a portion of the advisory fee charged to you to your Advisory Representative. While
no Advisory Representative can exceed the fees schedules outlined below, each Advisory
Representative can negotiate and charge an advisory fee based on the fee schedules
below. The amount of the fee is not commensurate with education or tenure in the
industry. Therefore, there is another Advisory Representative who charges more or less
than the fee you are being charged for similar services.
The advice provided by Advisory Representatives often involves recommendations to invest
assets according to an asset allocation primarily involving mutual funds, UCITs (UK pensions
accounts), exchange traded funds, stocks, bonds, alternative products and other types of
securities. Recommendations include investing in various share classes. Different share classes
of securities involve different fee structures and internal costs. Institutional shares are often the
least expensive from an internal cost perspective; however, the transaction fees can be higher.
It is important you understand the internal cost structure of the various share classes. Additional
information about costs and the various share classes can be found in the prospectus.
Mutual funds and UCITs offer the securities in various share classes. Different share classes are
priced differently and share classes other than institutional share classes will involve higher
internal costs that over time will cost you more. Institutional share classes often have higher
trading costs. A client needs to consider the amount being invested and the length of anticipated
holding to make a decision as to the share class most suitable to the client. Representatives will
select the lowest share class funds available and appropriate to the situation. However, in
selecting the lowest share class, trading costs are sometimes higher. Selecting the lowest share
class appropriate to the situation does not imply the lowest cost share class. Instead, your
Advisory Representative will select what they deem lowest cost for the situation. Representatives
consider the anticipated holding period, cost structure, and administrative and transaction costs
associated with selecting a share class. However, there is no way to predict the future and there
could be occasions where a holding is liquidated sooner or held longer resulting in higher costs
to the client. Additional information about share classes can be found in an Investor Alert issued
by the Securities and Exchange Commission at https://www.investor.gov/additional-
resources/news-alerts/alerts-bulletins/investor-bulletin-mutual-fund-classes and

Form ADV Part 2A                                                                        12 | P a g e

Blacktower Financial Management (US) LLC                                          March 27, 2026

https://www.investor.gov/additional-resources/news-alerts/alerts-bulletins/investor-bulletin-
mutual-fund-classes. Additionally, the SEC and FINRA provides investor information at
www.sec.gov and www.finra.org.
It is important to note that institutional share classes for UK pension assets are often not available
unless the client meets the minimum investment amount, which is often high.
The following fees for advisory services are negotiable. Fees are not based on a share of capital
gains upon or capital appreciation of the funds or any portion of the funds.

A. Pension Plan Investment Services

   There are multiple fees clients will pay when electing to transfer a U.K. pension to a Self-
   Invested Personal Pension (“SIPP”) or Qualifying Recognised Overseas Pension Scheme
   (“QROPS”) including:
       •   FCA required suitability report costs (required for defined benefit transfers)
       •   Initial planning and analysis fee
       •   Ongoing asset management fees
       •   Discretionary fund manager fees
       •   Investment platform, custodian, and trustee fees, and transaction and dealing fees.

   Clients will pay an initial fee covering time and services for analysis and planning, advice,
   consultation, and review and establishment of a SIPP, QROPS, or another applicable plan.
   The initial fee is deducted directly from the value of the assets transferred, unless directly paid
   by the client. The fee is a contingent fee, meaning client will only pay the fee if the client elects
   to transfer their pension. This is a conflict of interest because there is an incentive to
   recommend a transfer in order to receive compensation. To mitigate this conflict of interest
   this disclosure is provided, and clients should discuss the transfer with another professional.
   The fee is a percentage fee based on the value of the pension assets to be transferred as
   further described below.

   In addition to the initial fee, if the client has a defined benefit plan the client will pay a
   fee to a U.K. qualified Advisor to prepare the U.K. suitability report, which can be £5,000
   or more, depending on the UK Advisor, the value of UK pension assets, and the time
   frame the report is needed. The fee is paid direct to the UK Advisor for the report and is not
   determined or set by the US or shared with US or its advisory representatives. UK pension
   transfers with safeguarded benefits in excess of £30,000 are subject to review and analysis
   by a UK regulated adviser, unaffiliated with us. The suitability report fee is charged to the client
   and is an added cost incurred by the client, whether or not the client decides to move forward
   with the pension transfer. The cost of the suitability report will be invoiced to the client or will
   be deducted directly from the pension asset once the transfer to the SIPP has been
   completed. In certain circumstances your Advisory Representative can agree to cover the
...

Item 7: Types of Clients

We offer investment advisory services to US persons, US connected persons living
abroad with US retirement assets, and UK expatriates with residency in the United States
of America. Although there is no minimum amount requirement, transferring the client's
former UK pension scheme or US retirement account must be in the best interest of the
client. With respect to UK pension assets, we adhere to strict requirements of the Her
Majesty's Revenue and Customs (HMRC) and other applicable regulations in order to be
compliant on UK pension transfers.
Our services are appropriate for individuals both with high net worth (i.e., clients with a
net worth of $2,200,000, exclusive of primary residence or has $1,100,000 under
management with us) and other than high net worth. Further, certain of our advisors have
experience assisting US retirement plan sponsors with retirement consulting services.