Brighton Wealth Management Inc

Item 5 - Fees and Compensation

Portfolio Management Services Fees
For portfolio management services, Brighton Wealth charges an annual fee of up to 1.00% of assets under
management. Brighton Wealth deducts fees and/or bills clients for investment advisory services quarterly in
advance, based upon the market value of the assets on the last business day of the previous quarter. Prorated
adjustments are made for account deposits and withdrawals made during a fee period.

Other fee payment arrangements can be negotiated on a case-by-case basis. Legacy clients may be subject to a
different fee schedule and payment arrangement from the one listed here. Such fees and payment arrangements
will be clearly listed in the advisory agreement signed by the client and the firm. We may modify the fee at any
time upon 30 days’ written notice.

The fee is deducted from the client's account held at the custodian. The client authorizes us to debit the fee from
the client’s account. If insufficient cash is available to pay such fees, securities in an amount equal to the balance of
unpaid fees will be liquidated to pay for the unpaid balance. We may deduct the fee from a single, Client-
designated account to facilitate billing. We encourage you to carefully review the statements you receive from the
qualified custodian. If you have questions about your statements, or if you did not receive a statement from the
qualified custodian, please call our office number located on the cover page of this brochure. In limited cases, we
may invoice the client directly for the payment of fees. In the limited event that Brighton Wealth bills the client
directly, payment is due upon receipt of the invoice.

Our annual fee is exclusive of and in addition to brokerage commissions, transaction fees, and other related costs
and expenses, which will be incurred by the client. However, we will not receive any portion of the commissions,
fees, and costs. Please see Item 12 – Brokerage Practices for further information on brokerage and transaction
costs.

Brighton Wealth Management, Inc.
Form ADV Part 2A

The Investment Advisory Agreement between Brighton Wealth and the client will continue in effect until
terminated by either party by written notice in accordance with the terms of the Investment Advisory Agreement.
Upon termination, Brighton Wealth shall refund the pro-rated portion of the advanced advisory fee paid based
upon the number of days remaining in the billing quarter.

Negotiability of Fees: We allow Associated Persons servicing the account to negotiate the exact investment
management fees within the range disclosed in our Form ADV Part 2A Brochure. As a result, similarly situated
clients could pay different fees. Further, our annual investment management fee may be higher than that charged
by other investment advisors offering similar services/programs.

Billing on Cash Positions: The firm treats cash and cash equivalents as an asset class. Accordingly, unless otherwise
agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of
assets under management for purposes of calculating the firm’s advisory fee. At any specific point in time,
depending upon perceived or anticipated market conditions/events (there being no guarantee that such
anticipated market conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for
defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts
could miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could
exceed the interest paid by the client’s cash or cash equivalent positions.

Billing on Margin Balances: To the extent that a client maintains an outstanding margin balance at the end of a fee
period, the outstanding margin balance will be netted against the client’s investment assets in calculating the
client’s assets under management for the purpose of determining Brighton Wealth’s fee. As a result, in addition to
understanding and assuming the additional principal risks associated with the use of margin, clients authorizing
margin are advised of the potential conflict of interest whereby Brighton Wealth is incentivized to recommend the
client terminate the use of margin in order to increase the asset base upon which Brighton Wealth’s fee is based.
Accordingly, the decision to use and/or terminate the use of margin is left totally to the discretion of client.

Periods of Portfolio Inactivity: The firm has a fiduciary duty to provide services consistent with the client’s best
interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to
determine if any changes are necessary based upon various factors, including but not limited to investment
performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances,
and changes in the client’s investment objectives. Based upon these and other factors, there may be extended
periods of time when the firm determines that changes to a client’s portfolio are neither necessary nor prudent.
Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee will continue to
apply during these periods, and there can be no assurance that investment decisions made by the firm will be
profitable or equal any specific performance level(s).

IRA Rollover Considerations: As a normal extension of financial advice, we provide education or recommendations
related to the rollover of an employer-sponsored retirement plan. A plan participant leaving employment has
several options. Each choice offers advantages and disadvantages, depending on desired investment options and
services, fees and expenses, withdrawal options, required minimum distributions, tax treatment, and the investor's
...

Item 7 - Types of Clients

We generally offer investment advisory services to individuals, pension and profit-sharing plans and their
participants, trusts, estates, charitable organizations, corporations, and other business entities.

Brighton Wealth requires a minimum of $500,000 to open and maintain an advisory account. In our sole discretion,
we may waive this requirement. This requirement can be met by combining two or more accounts owned by you
or related family members.