Bradley Wealth LLC

FEES AND COMPENSATION
Advisory Fees
   We earn fees and compensation by providing investment management services, selecting separately managed
   programs, recommending alternative investments, and offering financial planning and consultation services.
   Our standard fees for services are as follows:
   1. Investment Management Services
   Our fee schedule for investment management services is as indicated below:
                           Market Value of Portfolio               Max. Annual Fee
                               First $ 250,000                          1.95%
                               Next $ 250,000                           1.80%
                               Next $ 500,000                           1.60%
                               Next $1,000,000                          1.30%
                               Over $2,000,000                          1.00%

                                      Quarterly Fee Calculation Formula
          (Blended Annual Rate) x (Value of Assets under Management at calendar quarter-end)/365
                              x (The number of days in the calendar quarter)

BRADLEY WEALTH BROCHURE                                                                                             6

   Our fee schedule for investment management services is negotiable. The final fee is outlined in our investment
   management agreement. Please also review the Types of Clients section for more details regarding our
   minimum investment value of $250,000. We also reserve the right to accept investment accounts of lesser
   value based upon specific criteria such as the anticipation of additional assets, the dollar amount of assets to be
   managed, related accounts, account composition, etc., that we deem pertinent.
   •   Please Note. There is no Pontera Platform Subscription Fee. Clients will not pay Pontera
       subscription or platform fees for the retirement savings accounts and assets we access through the platform.
       The value of the retirement accounts or assets managed on the platform will be included in a client’s
       aggregate asset under management for advisory fee billing purposes.
   2. Third-Party Asset Management Services
   Depending on the program, the aggregate fee for third-party asset management services ranges from 1.25% to
   1.95% per annum. The fees are based on the account value and rate determined by the specific third-party asset
   manager. Generally, the per annum amount includes the fees assessed by our firm. The final fee and other
   charges are outlined in the third-party asset manager’s Brochure (Form ADV Part 2A), management agreement,
   and other disclosure documents. Our arrangements with third-party asset managers are typically sub-advisory
   or referral-based (i.e., pursuant to a solicitor’s arrangement). When we receive referral fees from a third-party
   asset manager, clients must acknowledge receipt of a disclosure statement that outlines the referral
   compensation.

   3. Automated Investment Advisory Services
   Our annual fee for this platform is an asset-based fee not to exceed 1.50% which is shared between our firm and
   Betterment. This fee will be prorated and billed on a monthly basis in arrears, based on your average daily
   balance for the prior month. Betterments share of the fee is a wrap fee that includes all the services provided by
   Betterment and Betterment Securities through the Betterment for Advisors platform, including advisory
   services, custody of assets, execution and clearing of transactions, and account reporting. Betterment collects
   wrap fees directly from you pursuant to the terms of the sub-advisory agreement between Betterment and you.
   We also pay a fixed monthly fee to Betterment for the use of the platform.
   4. Financial Planning & Consultation Services
   Our fees for financial planning and consultation services are assessed at either fixed fees or an hourly rate. The
   annual fixed fees generally range from $2,500 to $10,000, and hourly fees are assessed at a fixed rate of $150.
   Our annual fees for financial planning services are negotiable; however, the hourly rate is non-negotiable.
   If, after the first year, a client chooses ongoing financial planning services, we will assess fees for financial
   planning and consultation services annually. The annual fees for ongoing financial planning services are
   assessed at the most beneficial fee structure (i.e., fixed fees or an hourly rate) as determined by the client’s
   financial circumstances, particular ongoing needs of a client, value of investable assets, scope of services, the
   complexity of a client’s financial situation, and frequency of the planning/consultative sessions required.
   We assess fees for ongoing financial planning services on the first anniversary of the client’s initial engagement,
   and on each anniversary, the financial planning agreement remains in effect.
   5. Retirement Plan Advisory Services
   Our retirement plan consulting services fees are assessed at an annual rate of up to 1 basis point (0.01%). The
   fees are based on a percentage of the market value of includable retirement plan assets. Our fees for retirement
   plan advisory services are negotiable.
   6. Alternative Investment Advisement Services
   Fees for alternative investment advisement are assessed in accordance with the investment management fee
   schedule herein. When calculating advisory fees, the value of any alternative investment, which generally
   reflects the initial purchase (or the most recent valuation reported by the issuer or account custodian), is
   included as a part of a client’s aggregate “assets under management” (i.e., included with the value of all advisory
   accounts).
   7. Financial Education Seminars
   There are no fees for financial education seminars.
Billing Procedures
   The specific details of our billing procedures are as follows:
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Types of Clients
   Our firm generally provides investment advice to individuals, high net-worth individuals, pensions, profit-
   sharing plans, corporations, trusts, estates, charitable organizations, and other business entities.
   Investment Management Services
   We prefer that clients make an initial minimum investment of $250,000. Nonetheless, we reserve the right to
   waive our minimum requirement based on other criteria (e.g., pre-existing relationships, related accounts, the
   anticipation of additional assets, etc.) that we deem pertinent.
   Third-party Investment Management Services
   Notwithstanding our minimum investment value stated herein, the minimum investment value for third-party
   asset management services may vary according to the program or platform.
METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS
Methods of Analysis and Investment Strategies
   We generally use fundamental analysis methods to evaluate individual securities. Our primary sources of
   information include, but are not limited to, research materials prepared by others, the inspection of corporate
   activities, financial newspapers and magazines, annual reports, prospectuses, and corporate press releases.
   Fundamental analysis consists of calculating financial ratios and reviewing cyclical trends of industries in
   conjunction with monetary policy indicators to assess the overall performance and profitability of markets and
   companies.

BRADLEY WEALTH BROCHURE                                                                                             9

   Our investment management strategies consist of strategic asset allocation, diversification, and risk
   management. Based on a client’s financial circumstances, investment objectives, and risk tolerance, we typically
   recommend stocks, bonds, mutual funds, exchange-traded funds, real estate investment trusts, third- party
   asset managers, and if suitable alternative investments for portfolio holdings.
   Depending on a client’s financial circumstances and the suitability of the strategy, we may also recommend
   third-party asset managers, alternative investments, and more tactical and short-term strategies.
   As a part of our analysis method and due diligence of third-party asset managers, we review and evaluate the
   investment style or methodology, years in the business, assets under management, regulatory status, and
   relative portfolio costs. After determining that a third-party asset manager meets our initial selection
   requirements, we continue to monitor the performance of the third-party asset managers to ensure that the
   platforms are continually providing the performance and value for which they were initially selected. We will
   provide clients with a copy of each third-party asset manager’s Brochure (Form ADV Part 2A), which includes
   information regarding methods of analysis and investment strategies.
   As a part of our due diligence for alternative investments, we review, amongst other factors, the investment
   strategy, performance, reputation, financial strength, reporting methodologies, and pricing criteria of the issuer
   or company that manages the alternative investment.
   When considering alternative investments as a part of a client portfolio, we consider the client’s net worth or
   annual income, other financial circumstances, and comprehensive investment goals. Clients must also
   acknowledge an understanding of the various risk factors that are associated with such investments. Alternative
   strategies are optional, and clients are under no obligation to consider or accept our recommendations relative
   to any investment in an alternative strategy.

Material Risks of Methods of Analysis and Investment Strategies
   INVESTING IN SECURITIES INVOLVES A RISK OF LOSS THAT CLIENTS SHOULD BE
   PREPARED TO BEAR.
   Notwithstanding the method of analysis or investment strategy employed, there is no guarantee that portfolio
   holdings or investment assets will achieve the desired investment objectives. Clients could experience losses by
   investing based on our strategies, and the client alone will bear such losses. The value of investment assets may
   be affected by one or more of the following risks, any of which could cause an investment’s return, price of
   shares, or yield to fluctuate:
   •   General Market Risk. Markets can, as a whole, go up or down on various news releases or for no
       explanation. This uncertainty means that, at times, the price of specific securities could go up or down
       without real cause and may take some time to recover any lost value. Adding additional securities may not
       help minimize this risk since market fluctuations generally affect all securities. Therefore, market
       fluctuations will ultimately affect a client’s portfolio holdings.
   •   Interest Rate Risk. Changes in interest rates will affect the value of a portfolio’s holdings invested in
       fixed-income securities. The value of fixed-income securities is more inclined to decrease as interest rates
       increase. This decrease in value may not be offset by income from new investments or other portfolio
       holdings. Interest rate risk is generally greater for fixed-income securities with longer maturities.
   •   Credit Risk. An issuer or guarantor of a fixed-income security may be unable or unwilling to make timely
       payments of interest or principal or honor its obligations otherwise. The issuer or guarantor may default,
       causing a loss of the entire principal amount of a security. An issuer’s credit rating reflects the degree of
       risk for a particular security. There is the possibility that the credit rating of a fixed-income security may
       be downgraded after purchase, which will adversely affect its value and a client’s portfolio holdings.
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