Brackenwood Capital Management LLC

Item 5 Fees and Compensation
How We Are Compensated
We charge clients an annual asset-based fee, billed quarterly in advance for our investment management services.
We have a single breakpoint at $1 million of assets under management. The fee is assessed on a straight tier,
meaning all client account assets are charged at a single rate that declines as account asset levels increase. For
the benefit of discounting your asset-based fee, we will aggregate accounts for the same individual or two or more
accounts within the same household.

  Assets under Management          Annual Fee
  Less than $1 million             .85%
  $1 million and above             .60%

The account value is billed based on the value determined by the client’s qualified custodian at the end of the
calendar quarter. If a client account is opened during the quarter, we will prorate the fee for the number of days
the account is open in the quarter. We bill our clients for investment management services via automatic fee
deduction through the client’s qualified custodian. The client authorizes this in BCM’s client agreement as well as
the custodial account opening paperwork.

Our fees may be negotiable on a client-by-client basis. Client facts, circumstances and needs will be considered
in determining the fees we charge. These include the complexity of the client’s situation, assets to be placed under
management, anticipated future additional assets, related accounts, portfolio style, and account composition,
among other factors. The specific annual fee applicable to your relationship with us will be identified in the written
client agreement between us.

Financial planning clients are billed at a maximum hourly rate of $250. Our hourly rate may be negotiable.
Financial planning clients are billed by direct invoice.

Refunds in the Event of Termination
You have the right to terminate our agreement without penalty within five business days after entering into an
agreement with us. Clients may terminate our services at any time after that by providing written notice to us.

Investment management clients will receive a prorated refund of pre-paid fees that we have not yet earned. We
will stop providing investment management services on your account(s) the day we receive your written
notification of termination (unless you request a specific date of termination of service in the future) or when
your account transfers out, whichever is sooner.

For financial planning and consulting services clients, if an agreement is terminated prior to completion of the
services, we will refund unearned fees (i.e., the refundable deposit received) as described in the client agreement.
Fees will be prorated based on the number of hours worked and the deliverables produced. As a written analysis
or plan is typically drafted after the bulk of the analyses and reviews have been completed, we will not generally
provide a written report to a client if the agreement is terminated prior to completion of the services simply
because we will not have the data available to complete such a report. If we have completed portions of a written
report that we feel confident are accurate without any further reviews or analysis, we will provide those
completed portions to the client at the time of termination.

Other Fees and Expenses
Depending on the type of account and where that account is held, clients may incur additional fees outside of
BCM’s advisory fees. Examples of other fees include custodial account fees; brokerage transaction fees; security
exchange fees; and mutual fund fees.

All fees paid to BCM for advisory services are separate and distinct from the fees and expenses charged by mutual
funds, ETFs, ETNs, structured notes and other investment vehicles. These fees will generally include a
management fee, other fund expenses, and a possible distribution fee. These fees are deducted from the fund
internally and reduce overall return. We typically employ institutional and other no-load share classes of the
mutual funds for client portfolios. You can invest in some of these mutual fund or mutual fund share classes
directly, without our services, and the cost could be more or less than what you pay through us. Accordingly, you
should review both the fees charged by the funds and our fees to fully understand the total amount of fees you
will pay in relation to the services we offer.

Neither BCM nor any of its supervised persons accepts compensation for the sale of securities or other investment
products, including sales charges or service fees from the sale of mutual funds. For information on our brokerage
practices, please refer to the Brokerage Practices section of this Brochure.

Item 7 Types of Clients
BCM provides financial services to individuals, small businesses, and trusts. We do not have any minimum
requirements for clients to work with us.