Brighton Securities Corp

Item 5 - Fees and Compensation

Wells Fargo Wrap Programs
(Personalized Unified Managed, FundSource, PIM, Asset Advisor and Custom Choice)
Your account will carry an annual management fee that ranges from 0.25% to 3.00% and is documented in the
advisory agreement between you and your adviser. Your advisory fee may be higher or lower than what you
would pay in a brokerage account where commissions are negotiated without advisory services.
Your advisory fee is influenced by your account value, the program you select, and the level of service you
request. Your adviser may negotiate your fee based on your individual circumstances and may group related
accounts to meet minimum account size requirements or to determine your overall fee. When setting your fee
schedule your adviser evaluates factors such as the complexity of your account, your financial condition, the
assets you ask us to manage, any expected future contributions, related accounts, your preferred portfolio
approach, and your account structure. Discounts that are not generally available may be offered to family
members and friends of associated persons of our firm.

Brighton Securities may also negotiate fees.
All accounts in any Wells Fargo Wrap Program pay a management fee on eligible assets. This management
fee covers advisory execution, custodial, and reporting services. Brighton Securities receives a portion of the
wrap fee for our services. Brighton Securities does not act as principal on program assets. Program restrictions
prohibit the receipt of mark-up, mark-downs, and 12b-1 fees on program assets.
To the extent that mutual funds are used within your program, we primarily utilize no‑load or institutional share
classes when available, subject to program and platform availability, fund minimums, and share‑class eligibility
rules. You may pay internal expenses charged by the mutual funds in which your assets are invested. Such
fees are separate from your annual management fee.
Non-program transactions within your FundSource account may charge a $6.90 fee. Additionally, you may pay
certain account service fees charged by First Clearing, such as annual IRA fees or wire fees which are also
separate from your annual management fee. For a full list of service fees, please see Brighton Securities Fee
Disclosure available on our website https://www.brightonsecurities.com/disclosures .
Unless you and your adviser agree otherwise you authorize us to have First Clearing deduct your quarterly
advisory fee from your account at the rate stated in your program agreement’s fee schedule. Fees and other
charges are deducted from the cash sweep and money market positions in your account to the extent
available.
Program fees are charged quarterly in advance. Your initial fee is calculated on the date your account is
accepted into the program and is prorated for the remainder of that calendar quarter. Future fees are
calculated at the start of each calendar quarter based on the value of your total account value which includes
the long and short market value of all securities and mutual fund positions in your account as applicable on the
last business day of the prior quarter.
A fee adjustment may be made during a fee period if you make a withdrawal or deposit additional funds or
securities. If you make a net addition or a net withdrawal in a calendar month, your account will be charged or
refunded a portion of the quarterly fee. This adjustment is applied in the month following the net addition or net
withdrawal and is based on the value of your account assets at that time. Brighton Securities may apply
additional fee adjustments on a case-by-case basis. Fee adjustments are not made based on appreciation or
depreciation of your account assets during the quarter.
You should review your program brochure for additional details.

First Clearing Cash Sweep Program
Our clearing firm, First Clearing, offers a cash sweep program as the default vehicle for eligible accounts. The
sweep holds operational cash used to pay advisory fees, fund withdrawals, meet recurring cash needs, and to
hold cash while you wait to reinvest. Available balances are automatically swept into interest‑bearing deposit
accounts at one or more FDIC (“Federal Deposit Insurance Corporation”) -insured banks, which may include
an affiliate of our clearing firm. In low‑rate environments, the yield on sweep balances may not offset advisory
fees, and the effective yield may be negative. You may opt out and request a money market fund instead;
money market funds are securities with their own risks and expenses and are not purchased or liquidated
automatically to cover fees or withdrawals. For economic benefits and conflicts related to the sweep program,
including revenue sharing, see Item 12, Brokerage Practices. As well, for additional details please refer to the
cash sweep program disclosure statement available on our website
https://www.brightonsecurities.com/disclosures .

Mutual Fund Direct Advisory Accounts
Brighton Securities offers these wrap fee programs to you, which are sponsored by the mutual fund company.
The mutual fund company acts as the qualified custodian under Rule 206(4)2 of the Investment Advisers Act.

These programs allow you to hold advisory accounts directly with the mutual fund company in share classes
that do not have an upfront or deferred sales charge, commonly known as no load funds.
The advisory fee for these accounts may range between 0.25% and 2.00% annually. The mutual fund
company calculates and deducts the fee either quarterly in arrears or quarterly in advance. Brighton Securities
receives a portion of the wrap fee for the services we provide. Brighton Securities does not receive 12b1 fees
under these arrangements. However, you may pay the internal expenses charged by the mutual funds in which
your assets are invested. Additional service fees may apply, such as IRA fees or wire fees. You agree to allow
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Item 7 - Types of Clients

Brighton Securities provides advisory services to the following types of clients:
• Individuals (other than high net worth individuals)
• High net worth individuals
• Pension and profit-sharing plans
• Charitable organizations
• Estates

• Trusts
• Corporations or other businesses not listed above