Bolton Securities Corp

ITEM 5 – FEES AND COMPENSATION

A. Asset-based Advisory Fees and Compensation

Asset-based advisory fees are negotiable between the client and IAR. The factors considered in the advisory
fee include the specific nature of services rendered, the complexity of a client's investment management
needs, and/or the value of a client's assets under management. The maximum fee that can be charged to
the client is 2.5%. Some of BGAM’s advisors may adhere to a static fee schedule for their own clients within
the Company’s stated asset based advisory fee range.

The specific fee charged by BGAM in any account or client relationship is agreed upon and set forth in the
client’s written agreement with BGAM. BGAM will generally bill its fees on a quarterly basis and clients are
billed at the start of each calendar quarter. Fees will be deducted from the client’s account by the client
granting BGAM authorization to directly debit fees from the accounts. Accounts initiated or terminated
during a calendar quarter will be charged a prorated fee based on the number of days in the period during
which BGAM provided advisory services. Management fees shall also be prorated for each capital
contribution and withdrawal made during the applicable calendar quarter, except for de minimis
contributions and withdrawals. BGAM’s fees are exclusive of brokerage commissions, administrative
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transaction charges, and other related costs and expenses which shall be incurred by the client.

At its discretion, BGAM can consider a client’s request for an alternative fee arrangement. In addition,
BGAM reserves the right to change its fee schedule for all clients or selected clients for any reason.

        Account Fees for Services in Addition to Investment Management

In accounts that are not subject to a wrap fee, IARs may also assess a fee to cover any ticket or transactional
fees they are assessed because of a trade in your account. Due to the design of the Custodian’s or its
introducing broker-dealer’s trading and account management systems, the ticket charge typically must be
assessed in a way that reflects as a commission in its systems. While the system requires the ticket charge
assessment to be reflected this way, a ticket charge assessment only reflects the passing through of trading
costs to the investors and does not reflect additional compensation to the IAR. Ticket charges pass through
assessments are processed at the exact ticket charge that is assessed to the IAR without any markup.

If you transact in fixed income instruments in your non-wrap fee based advisory account, you will bear
administrative transaction charges for purchases, sales and exchanges in your Account. If your account is
held in custody at Pershing, LLC, BGC will act as agent on your behalf when you transact in fixed income
instruments and will not also represent the person or entity on the other side of the transaction. Any fixed
income trading in your account conducted at BGC will be done on an agency basis only and not as an agency
cross transaction. (See Item 11 below for a further explanation of agency cross transactions. You authorize
BGC to deduct from your Account the transaction charges and other fees applicable to your Account. The
transaction charges are paid to BGC to defray costs associated with trade execution; however, these are
not directly and proportionately related to transaction-related expenses of BGC and are a source of revenue
to BGC for the trading services provided. The maximum administrative transaction charges for each fixed
income instrument transaction are the greater of $50.00 or 10 basis points (.10% of principal). For Treasury
Bills and Notes, the maximum charge is $25 or 2 basis points (.02% of principal), value whichever is greater.
The transaction charges are applied by BGC and are not directly shared with BGAM or shared with its IARs.
However, because BGC and BGAM operate under a common control and ownership structure, BGAM will
indirectly benefit from any fees, commissions or transactions charges that are paid to BGC. The
administrative transaction charges are in excess of advisory fees paid to BGAM and are subject to reduction
at the discretion of the BGC trading desk. Because of these practices and/or in certain instances BGAM will
be unable to achieve the most favorable execution of client transactions and this practice will result in the
client incurring higher costs and paying higher fees.

Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a
fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to BGAM’s fees. All
the foregoing costs should be discussed with your IAR.

Clients are responsible for clearing, custodial, transaction and miscellaneous charges, such as a postage or
confirmation fees, that are passed onto the client from the BGAM’s clearing broker-dealer, and in the case
of trade confirmation and annual account fees, contain a mark-up included by BGC.

In your account agreement with the Custodian, you have authorized the Custodian to deduct from your
account the transaction charges and other fees applicable to your account. The transaction charges are paid
to the Custodian to defray costs associated with trade execution; however, these costs are not directly or
proportionally related to transaction-related expenses of the Custodian and are a source of revenue to it
for the brokerage services it provides.
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The Schedule of Service Fees and administrative transaction charges applicable to your account may be
found at https://boltonglobal.com/doc/ScheduleOfServiceFees.pdf or requested from BGAM or your IAR.
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ITEM 7 – TYPES OF CLIENTS

BGAM provides asset management services to individuals, high net worth individuals, banks, trusts, estates
and charitable organizations, corporate pension and profit-sharing plans, and institutions.