Build Whale Inc

ITEM 5 – ACCOUNT, FEES, AND COMPENSATION
A.       Compensation

Whale Deposit Program
Whale will charge the Client an ongoing fee (“Advisory Fee”) of a maximum 1% net of the yield earned
in the Client’s money market account. The ongoing charges will be calculated monthly, in arrears, and
will be debited from the yield prior to the transaction into the client’s account. Whale will have
discretion to reduce or waive the percentage of fees charged to the extent the yield on the Client
Account decreases.

For example, if a client’s deposit is in the amount of $1,000, and earns a 5% yield monthly, the client
would pay $1 monthly. As the account balance fluctuates, the 5% yield, less the 1% charged for ongoing
services, will vary.

Whale Grow Program
Whale will charge the Client $3 per month of the Client’s Account. Whale will directly debit the
Advisory Fee from the Client’s advisory account (the “Account”). 1 The Advisory Fee excludes all

1 While the “Account” applies to both the Whale Deposit Program and Whale Grow Program, an
Account will generally be in reference to the Client’s investment advisory account in connection with
the Whale Grow Program.

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brokerage transaction, custodial, and/or ETF fees associated with any trades related to the Account
(“Third-Party Fees”).
B.       Payment of Fees
Advisory Fees and Third-Party Fees (discussed below) are deducted from the Client’s Account. The
Advisory Fees are charged monthly in arrears.

At our discretion, we may waive or reduce, our advisory fees.
C.       Third-Party Fees
In addition to Advisory Fees, Clients will incur Third-Party Fees, which consist of brokerage,
transaction, and custodial fees charged by the Broker-Dealer and Custodian, as well as fees charged by
the underlying ETFs that comprise the Model Portfolios.
Whale’s fees exclude brokerage commissions, transaction fees, and other related costs and expenses
which will be incurred by the Clients. Such charges, fees and commissions are charged by unaffiliated,
third parties. Such fees are exclusive of and in addition to Whale’s Advisory Fee, and Whale will not
receive any portion of such fees.
Please see Item 12 Brokerage Practices of this Brochure regarding brokerage.
D.        Other Fees:
ETFs charge fees to cover the costs of managing the underlying ETF in the form of an expense ratio.
These fees typically cover the ETF’s operating expenses, management fees, marketing costs, custodial
fees, etc. These fees are entirely separate and distinct from Whale’s Advisory Fee. The expense ratio of
each ETF included in the portfolios is outlined in the respective ETF prospectus. Prospective Clients
will receive copies of such prospectus prior to selecting a Model Portfolio. Such fees are exclusive of
and in addition to Whale’s Advisory Fee, and Whale will not receive any portion of such fees.

Clients may terminate our services upon move out by requesting an Outgoing ACH through the Build
Whale App. We will be notified of your move out when your landlord submits a summary of move-out
charges, such as damages or missed rent, which is deducted from your deposit. The remaining balance
will be instantly unlocked in your account and available for withdrawal to the bank account of your
choice. Clients may wish to retain our services after move out or may initiate a full withdrawal. Whale
provides various administrative and operational services to facilitate the efficient movement of funds,
account maintenance, and transaction processing.

To help offset the costs associated with these services, Whale may recover certain administrative
expenses through the following reimbursements:

                                       TRANSFERS – INCOMING

ACH                     Zelle              MoneyGram*           Wire Transfer*       Venmo

Standard:     $0        Standard:     $0   Standard:     $0     Standard (1-5        Standard: 2.5%
Expedited: $4.99        Expedited: $4.99   Expedited: $4.99     business days):      of      transfer
                                                                $0                   amount
                                                                                     Expedited: 3.0%
ACH Return Fee:
                                                                                     of      transfer
$25         per
                                                                                     amount
returned
transfer

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                           Standard: 3-5 business days. Expedited: Same Day.

                                        TRANSFERS - OUTGOING

ACH                   Zelle                  MoneyGram              Wire Transfer*         Venmo

Standard:     $0      Standard: $1.99        Not supported at        Standard (1-5         Standard: $1.99
Expedited: $6.99      Expedited: $4.99       this time               business days):       Expedited: $4.99
                                                                     $30 per wire

                                        ACCOUNT MAINTENANCE

Minimum Balance Fee                                                 Account Closure Fee

$2.99 per month                                                     $25 or total interest earned on the
                                                                    account (whichever is lower)
You can avoid the minimum balance fee when you meet at
least ONE of the following requirements during each
statement cycle:
...

ITEM 7 – TYPES OF CLIENTS
Whale provides investment advisory services to natural persons who are (i) legal U.S. residents, (ii) link and
maintain a checking account or other verified funding source with a U.S. bank or financial institution to their
Whale Account, and (iii) pass Whale’s identity verification protocols. The beneficiary of each Whale Account
must also be a U.S. resident with a valid social security number. Whale does not require a minimum account
size to open an account, as the opening amount is dependent on the size of the deposit required from your
landlord. However, in order to maintain an account with our services, an account minimum of $250 is
required. At our discretion, we may waive this minimum account size or implement a monthly “minimum

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balance” fee of $2.99 per month. Further, at our discretion, Whale may also combine account values to
meet the stated minimum.