Blue Jay Financial Group LLC

ITEM 5 - FEES AND COMPENSATION
Investment Management Fees and Compensation
Blue Jay Financial Group, LLC charges a fee as compensation for providing Investment
Management services on your account. These services include advisory and
consulting services, trade entry, investment supervision, and other account
maintenance activities. Our recommended custodian may charge custodial fees,
redemption fees, retirement plan and administrative fees or commissions. See
Additional Fees and Expenses below for additional details.

The fees for portfolio management are based on an annual percentage of assets under
management and are applied to the account asset value on a pro-rata basis and billed
quarterly in advance. The initial fee will be based upon the market value of the
portfolio on the day all of the assets arrive at the custodian and are believed to be a
complete receipt of the planned assets, prorated for the number of days remaining in
the quarter. Thereafter, the quarterly fee will be calculated on the market value of the
portfolio on the day the assets arrive for the calendar quarter. The market value will be
determined as reported by the Custodian. Unless otherwise agreed upon and stated in
Exhibit B of the Investment Management Agreement, fees are assessed on all assets
under management, including securities, cash, and money market balances. When
applicable and noted in Exhibit B of the Investment Management Agreement, legacy
positions will also be excluded from the fee calculation.

Our maximum annual advisory fee for accounts paying a percentage of assets under
management is 2.00% on all asset levels. The specific advisory fees are set forth in
your Investment Advisory Agreement. Fees may vary based on the size of the account,
complexity of the portfolio, extent of activity in the account or other reasons agreed
upon by us and you as the client. Additional deposits and withdrawals will be added
or subtracted from portfolio assets, as the case may be, which may lead to an

                                Blue Jay Financial Group, LLC
                             FORM ADV 2A Brochure March 26, 2026

adjustment of the account fee. In certain circumstances, our fees and the timing of the
fee payments may be negotiated. Our employees and their family related accounts are
charged a reduced fee for our services.

Unless otherwise instructed by the client, we will aggregate asset amounts in accounts
from your same household together to determine the advisory fee for all your accounts.
We would do this, for example, where we also service accounts on behalf of your minor
children, individual and joint accounts for a spouse, and/or other types of related
accounts. This consolidation practice is designed to allow you the benefit of an
increased asset total, which could cause your account(s) to be assessed a lower
advisory fee.

The independent qualified custodian holding your funds and securities will debit your
account directly for the advisory fee and pay that fee to us. You will provide written
authorization permitting the fees to be paid directly from your account held by the
qualified custodian. Further, the qualified custodian agrees to deliver an account
statement at least quarterly directly to you indicating all the amounts deducted from
the account including our advisory fees. At our discretion, our firm will allow
advisory fees to be paid by check as indicated in the Investment Advisory Agreement. You
are encouraged to review your account statements for accuracy.

Either Blue Jay Financial Group, LLC or you may terminate the management
agreement immediately upon written notice to the other party. The management fee
will be pro-rated to the date of termination, for the quarter in which the cancellation
notice was given and the unearned fee refunded to you. Upon termination, you are
responsible for monitoring the securities in your account, and we will have no further
obligation to act or advise with respect to those assets. In the event of client’s death
or disability, Blue Jay Financial Group, LLC will continue management of the account
until we are notified of client’s death or disability and given alternative instructions
by an authorized party.

Financial Planning Fees
Blue Jay Financial Group, LLC will negotiate the planning fees with you. Fees may
vary based on the extent and complexity of your individual or family circumstances
and the amount of your assets under our management. We will determine your fee
for the designated financial advisory services based on a fixed fee arrangement
described below.

Under our fixed fee arrangement, any fee will be agreed to in advance of services
being performed. The fee will be determined based on factors including the
complexity of your financial situation, agreed upon deliverables, and whether or not
you intend to implement any recommendations through Blue Jay Financial Group,
LLC. Fixed fees for financial plans range from $250 to $15,000.

Typically, we will complete and present the plan within 90 days of the contract date,
provided that you have provided us all information needed to prepare the financial

                                Blue Jay Financial Group, LLC
                             FORM ADV 2A Brochure March 26, 2026

plan. Fees are billed in two ways: (1) One hundred percent (100%) up front or (2)
one half (50%) of the estimated fee will be due and payable at the time you enter into
the financial planning agreement, with the balance due and payable at the time the
financial plan is delivered. Typically, fees $500 or less will be billed in full upon
entering the Agreement with our firm. You may terminate the financial planning
agreement by providing us with written notice. Upon termination, fees will be
prorated to the date of termination, and any unearned portion of the fee will be
refunded to you based on an hourly rate of $250.00. Services provided up to date of
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ITEM 7 - TYPES OF CLIENTS
We provide investment advice to individuals, employer sponsored retirement plans,
trusts, and charitable organizations. We have no minimum initial account value.

Philosophy is simple. There is a time for growth and a time to protect. Markets,
financial goals, and individual risk tolerances change over time. Too often we see
clients who have been involved in advisor relationships where investment holdings
simply stay static over time regardless of the investment landscape. Although we do
not believe that “market timing” is a strategy that will provide desired results on a
consistent basis over an extended period, there are times when evidence supports the need
to make when adjustments are made in an effort to reduce risk.

Blue Jay’s investment strategies and advice vary with each client. We determine
investments and allocation based upon predetermined objectives, risk tolerance,
time horizon, financial information, liquidity needs, and other suitability factors. Client
restrictions and guidelines may affect the composition and outcome of their portfolio.
Every client situation is unique, and Blue Jay may utilize one or more of the following
methods of analysis in formulating investment advice for a client:

                                 Blue Jay Financial Group, LLC
                              FORM ADV 2A Brochure March 26, 2026

Fundamental
This is a method of evaluating a security by attempting to measure its intrinsic value
by examining related economic, financial, and other qualitative and quantitative
factors. Fundamental analysts attempt to study everything that can affect the security's
value, including macroeconomic factors (like the overall economy and industry
conditions) and individually specific factors (like the financial condition and
management of companies). The end goal of performing fundamental analysis is to
produce a value that an investor can compare with the security's current price in hopes
of figuring out what sort of position to take with that security (underpriced = buy,
overpriced = sell or short). This method of security analysis is the opposite of technical
analysis. Fundamental analysis is about using real data to evaluate a security's
value. Although most analysts use fundamental analysis to value stocks, this
method of valuation can be used for just about any type of security.

Tactical
This is a method that allows us to make changes to a client’s portfolio based on
opportunities or risks that present themselves in the overall economic landscape.
This approach allows us the flexibility to make gradual or sudden changes in a client’s
portfolio and to adapt to the ever-changing market conditions.

Technical
This is a method of evaluating securities by analyzing statistics generated by market
activity, such as past prices and volume. Technical analysts do not attempt to measure
a security's intrinsic value, but instead use charts and other tools to identify patterns
that can suggest future activity. Technical analysts believe that the historical
performance of stocks and markets are indications of future performance.

Charting
This is a method used in technical analysis in which charts are used to plot price
movements, volume, settlement prices, open interest, and other indicators, to
anticipate future price movements. Users of these charting techniques believe that
past trends in these indicators can be used to extrapolate future trends.

Cyclical
This is a method of analyzing the investments sensitive to business cycles and whose
performance is strongly tied to the overall economy. For example, cyclical companies tend
to make products or provide services that are in lower demand during downturns in
the economy and in higher demand during upswings. Examples include the automobile,
steel, and housing industries. The stock price of a cyclical company will often rise just
before an economic upturn begins and fall just before a downturn begins. Investors in
cyclical stocks try to make the largest gains by buying the stock at the bottom of a
business cycle, just before a turnaround begins.

Top-Down Investing
This method involves evaluating the overall state of the economy (macroeconomic)
and then further evaluating the various components and sub-components in greater

                                Blue Jay Financial Group, LLC
                             FORM ADV 2A Brochure March 26, 2026

detail. For example, after evaluating the high-level economic environment, either on a
global or domestic scale, analysts further examine the various market and industrial sectors
in order to select those areas that are forecasted to outperform the overall market.
Analysts then further evaluate specific asset classes and the securities of specific
companies to determine an allocation or portfolio.

Thematic
This method takes a “top-down” approach to investing and involves making
investment decisions based on predictions about trends or other forward-looking
criterion, rather than on past market performance and indicators or the fundamentals of
a specific security. Blue Jay uses the following investment strategies when
managing client assets and/or providing investment advice:
     ●   Long term purchases. Investments held at least a year.
     ●   Short term purchases. Investments sold within a year.
     ●   Trading. Investments sold within 30 days.

Short sales
A short sale is generally the sale of a stock not owned by the investor. Investors who
sell short believe the price of the stock will fall. If the price drops, the investor can buy the
stock at the lower price and make a profit. If the price of the stock rises and the
investor buys it back later at the higher price, the investor will incur a loss. Short sales
require a margin account.

Margin transactions
When an investor buys a stock on margin, the investor pays for part of the purchase
and borrows the rest from a brokerage firm. For example, an investor may buy $5,000
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