Brown Wealth Management LLC

Item 5: Fees and Compensation

E. Important Disclosure – Custodian Investment Programs
Please be advised that certain of the firm’s investment adviser representatives are registered
with a broker-dealer and/or the firm is a broker-dealer or affiliated with a broker-dealer. Under
these arrangements, we can access certain investment programs offered through the broker-
dealer that offer certain compensation and fee structures that create conflicts of interest of
which clients need to be aware. As such, the investment adviser representative and/or the firm
may have an economic incentive to recommend the purchase of 12b-1 or revenue share class
mutual funds offered through the broker-dealer platform rather than from the investment
adviser platform.
Please note the following:
Limitation on Mutual Fund Universe for Custodian Investment Programs: Please note that as a
matter of policy we prohibit the receipt of revenue share fees from any mutual funds utilized for
our advisory clients’ portfolios. There are certain programs in which we participate where a
client’s investment options may be limited in certain of these programs to those mutual funds
and/or mutual fund share classes that pay 12b-1 fees and other revenue sharing fee payments,
and the client should be aware that the firm is not selecting from among all mutual funds
available in the marketplace when recommending mutual funds to the client.
Conflict Between Revenue Share Class (12b-1) and Non-Revenue Share Class Mutual Funds:
Revenue share class/12b-1 fees are deducted from the net asset value of the mutual fund and
generally, all things being equal, cause the fund to earn lower rates of return than those mutual
funds that do not pay revenue sharing fees. The client is under no obligation to utilize such
programs or mutual funds. Although many factors will influence the type of fund to be used, the
client should discuss with their investment adviser representative whether a share class from a
comparable mutual fund with a more favorable return to investors is available that does not
include the payment of any 12b-1 or revenue sharing fees given the client’s individual needs
and priorities and anticipated transaction costs. In addition, the receipt of such fees can create
conflicts of interest in instances (i) where our adviser representative is also licensed as a
registered representative of a broker-dealer and receives a portion of 12b-1 and or revenue
sharing fees as compensation – such compensation creates an incentive for the investment
adviser representative to use programs which utilize funds that pay such additional
compensation; and (ii) where the custodian receives the entirety of the 12b-1 and/or revenue
sharing fees and takes the receipt of such fees into consideration in terms of benefits it may
elect to provide to the firm, even though such benefits may or may not benefit some or all of
the firm’s clients.

Item 7: Types of Clients
RAI Wealth provides investment advice to many different types of clients. These clients generally
include individuals and high-net-worth individuals, families, trusts, estates, corporations, and
other types of business entities.
RAI Wealth does not require a minimum account size for its separately managed clients.