Broadhurst Financial Advisors Inc

Fees and Compensation

                                                                                         Form ADV Part 2A, Item 5

THIS SECTION IS REQUIRED. YOU MAY NOT OMIT THIS HEADING. You must answer each item. If an
item is not applicable, you must state that it is not applicable.

A. Describe how you are compensated for your advisory services. Provide your fee schedule. Disclose whether
the fees are negotiable.
FEE SCHEDULE
Broadhurst Financial Advisors is compensated by what the Client pays us, not commissions. The advisory fee
schedule is:
  Value of All Managed         Up to                       Per Quarter                 Annualized
  Accounts with Firm
  First $1.0 million           $1.0 million                0.3125%                     1.25%
  Next $1.5 million            $2.5 million                0.2500%                     1.00%
  Next $2.5 million            $5.0 million                0.2000%                     0.80%
  Next $5.0 million            $10.0 million               0.1750%                     0.70%
  $10 million and over         n/a                         0.1250%                     0.50%
In certain situations, our fees are negotiable. The advisory fees include trading costs but do not other nominal
custodial account maintenance fees.
For certain projects, our fee may be a fixed fee, quoted in advance. Fees are negotiated based on the scope,
complexity and deliverables required by the Client. Infrequently, we may provide advice based on an hourly
rate of $350 per hour.

B. Describe whether you deduct fees from Clients’ assets or bill Clients for fees incurred. If Clients may select
either method, disclose this fact. Explain how often you bill Clients or deduct your fees.
The firm withdraws advisory fees from the Client’s account on a quarterly basis. At the onset of the Advisory
Agreement, the Client authorizes the custodian, in writing, to debit the advisory fees from their account. Unless
the Agreement is terminated by the Client or the Advisor, it shall automatically continue. The firm sends a copy
of the invoice to the custodian at the same time it is sent to the advisory Client. The custodian also sends to the
Client a quarterly statement to the Client showing all disbursements from the custodial account, including the
amount of the advisory fees.

USE OF ALTERNATIVE INVESTMENTS
Registrant may, in certain cases, recommend non-traditional (or alternative) investments in order to assist in
the mitigation of clients’ federal income tax burden incurred as a result of an imminent liquidity event and/or the
receipt of an executive bonus. It is disclosed herein that these types of assets are purchased by a direct
subscription and as such, do not appear on the traditional custodial platform used by registrant in most cases.
In these cases involving the usage of alternative investments, Registrant shall charge a one-time administrative
fee based on the amount of the investment (at all times earned and applied).

These investments are available only to accredited investors and are typically used for tax mitigation and
reduction purposes, diversification and the like. Registrant herein discloses to the client that typically these
alternative investments pay a 6.0% to 7.5% commission to brokers which sells such products on a commission
basis. Client should understand the fact that registrant is a fee only practitioner and does not accept
commissions derived from the products which such registrant recommends. In fact, since the affiliated persons
of the registrant are not registered representatives of a registered broker dealer, it is impossible (as a matter of
law) for such associated persons to receive any commission income on the sale of products.

ALTERNATIVE INVESTMENT FEE SCHEDULE
Broadhurst Financial Advisors is compensated by what the Client pays us, not commissions. The advisory fee
schedule is:

 Value of Alternative Investment at Purchase     Up to            One Time Fee on Alternative Investment
 First $1.0 million                              $1.0 million     5.00%
 Next $1.5 million                               $2.5 million     4.00%
  Next $2.5 million                               $5.0 million    3.00%
  Next $5.0 million                               $10.0 million   2.00%
  $10 million and over                            n/a             1.00%
In certain situations, our fees are negotiable. The advisory fees do not include trading costs or other nominal
custodial account maintenance fees.

C. Describe any other types of fees or expenses Clients may pay in connection with your advisory services,
such as custodian fees or mutual fund expenses. Disclose that Clients will incur brokerage and other
transaction costs, and direct Clients to the section(s) of your brochure that discuss brokerage.
Clients will not incur transaction costs from the custodian. The advisor absorbs the trading costs on behalf of
the client. Clients will pay mutual fund expense ratios. Our portfolios of low-cost mutual funds typically have
blended expense ratios from 0.05-0.34%.

As discussed above at Form ADV, Part 2A., item 4, there are certain circumstances and cases in which
registrant will recommend the acquisition and usage of certain alternative investments in order for the advisory
client to reduce tax burdens under the federal income tax laws due to an unusual liquidity event and/ or as a
result of the receipt of executive compensation in the form of bonuses. In these circumstances, the registrant
will charge a flat administrative fee set equal to five (5%) percent of the investment. No fee shall ever be
payable more than six months in advance and all of the fee shall be fully earned and applied. The fee shall be
payable by the advisory client at the time of the acquisition of the alternative investment or investments.

D. If your Clients either may or must pay your fees in advance, disclose this fact. Explain how a Client may
...

Types of Clients

                                                                                   Form ADV Part 2A, Item 7

THIS SECTION IS REQUIRED. YOU MAY NOT OMIT THIS HEADING. You must answer each item. If an
item is not applicable, you must state that it is not applicable.

Describe the types of Clients to whom you generally provide investment advice, such as individuals, trusts,
investment companies, or pension plans. If you have any requirements for opening or maintaining an account,
such as a minimum account size, disclose the requirements.
Broadhurst Financial Advisors is engaged in the business of providing Wealth Management to affluent
individuals and families. The suggested minimum account size is $3,000,000. In certain situations, this
minimum is negotiable.

Occasionally, the Advisor provides investment advice to endowments, foundations and other 501(c)3 not-for-
profit organizations.

                        Methods of Analysis, Investment Strategies and Risk of Loss

                                                                                           Form ADV Part 2A, Item 8

THIS SECTION IS REQUIRED. YOU MAY NOT OMIT THIS HEADING. You must answer each item. If an
item is not applicable, you must state that it is not applicable.

A. Describe the methods of analysis and investment strategies you use in formulating investment advice or
managing assets. Explain that investing in securities involves risk of loss that Clients should be prepared to
bear.
INVESTMENT PHILOSOPHY
Generally, passive securities are better portfolio instruments due to low costs, tax efficiency and the discipline
imposed by their construction methodology. Passive funds capture asset class returns but do not style drift.
The passive funds from DFA are similar to index funds for obtaining asset class exposure yet offer additional
tax benefits. We also use “direct indexing” strategy for taxable accounts to allow for robust tax loss harvesting.

The Advisor facilitates the construction of risk-appropriate, globally-diversified, tax-efficient portfolios of low-cost
funds for the Client(s). The Client has been made aware that:
•       the Advisor does not pick individual stocks or sectors (no stock picking)
•       the Advisor does not attempt to time the market (no market timing)
•       the Advisor does not recommend actively managed mutual funds (no manager picking)

Research has shown that active management (i.e. stock picking and market timing) usually destroys value.
Furthermore, active funds have higher expense ratios, unnecessary loads & commissions, and therefore
usually underperform index benchmarks. Finally, active fund managers tend to style drift which has been
shown to make diversified portfolio construction difficult and efficient investing impossible.

As with any security, there is a risk of loss of some or all the value of the mutual fund securities we use. Clients
should be prepared to bear the risk associated with their particular target portfolio. The Client must inform the
Advisor if there are material changes in Client’s financial circumstances which might affect the way Client’s
assets are allocated. Changes in the Clients’ family life or financial circumstances typically may call for a review
of the appropriate model portfolio(s). Depending upon the Client’s needs and preferences, typically we meet 2-
4 times per year to discuss the investments and planning strategy.

The Advisor shall not have any liability for Client’s failure to inform the Advisor in a timely manner of any
material change in Client’s circumstances which might affect the manner in which assets are allocated, or to
provide the Advisor with any information as to Client’s financial status as the Advisor may reasonably request.

In general, the Advisor advises Clients on passive mutual funds, ETFs (exchange traded funds), municipal or
high-grade bonds, and U.S. government securities. However, while providing comprehensive investment
advice, BFA may address issues related to other types of assets that may be owned by the Client, such as real
estate, precious metals, company stock options and alternative investments.

B. For each significant investment strategy or method of analysis you use, explain the material risks involved. If
the method of analysis or strategy involves significant or unusual risks, discuss these risks in detail. If your
primary strategy involves frequent trading of securities, explain how frequent trading can affect investment
performance, particularly through increased brokerage and other transaction costs and taxes.
As with any security, there is a risk of loss of some or all the value of the mutual fund securities we use.
Investing in mutual funds involved the risk of loss. The Advisor strives to develop a risk-appropriate, globally-
diversified, tax-efficient investment portfolio for the Client. However, market risk is present, and the fund values
can fluctuate as the global capital markets fluctuate.

C. If you recommend primarily a particular type of security, explain the material risks involved. If the type of
security involves significant or unusual risks, discuss these risks in detail.

We primarily recommend mutual funds. We construct various models of mutual funds that vary from low risk to
high risk. For each Client, the Advisor strives to develop a risk-appropriate investment portfolio. If the Client is
in a high-risk portfolio, there is considerable equity market risk.