Circle Wealth Management LLC

Item 5: Fees and Compensation

We are compensated exclusively by our clients and do not share in the fees paid to Independent
Managers, custodians, broker/dealers, or any other provider. Circle fees are based on the overall
assets under management, for both discretionary and non-discretionary relationships. In addition,
when a client situation requires that we provide services in areas other than investment
management, such as consulting or family office services, we will offer those services for a flat
annual fee, determined by the complexity of the mandate and the requirements of the client. All
fees are mutually agreed upon between the client and Circle. Fees can vary based on several factors,
including the client’s specific circumstances/requests and the complexity of the account(s). Our
typical fees range from 24 bps to 85 bps.

Our advisory fees are prorated and invoiced quarterly in advance, based on either the market value
of the assets, which may include uninvested cash, on the last business day of the previous quarter
or the agreed upon quarterly flat fee. Our Investment Advisory Agreement and the custodial
agreements may authorize the custodian to debit the client’s account for our advisory fee and to
directly remit that advisory fee to us in compliance with regulatory procedures.

Our annual advisory fee shall generally (exceptions can occur) include investment advisory
services, and, to the extent specifically requested by the client, financial planning and consulting
services. In the event that the client requires extraordinary planning and/or consultation services
(to be determined in the sole discretion of Circle), Circle may determine to charge for such
additional services, the dollar amount of which shall be set forth in a separate written notice to the
client.

All fees paid to Circle for its services are separate and distinct from the fees and expenses charged
directly by the custodian(s) of the client’s account(s), transaction charges imposed by the broker-
dealer executing securities transactions for the client’s account(s), applicable fees charged by
qualified custodians associated with account maintenance/transfers, fees and expenses embedded
in ETFs and mutual funds held in or for the client’s account(s) and/or charged to the client’s
account(s) by investment managers, such as hedge funds and private equity partnerships,
Independent Managers, and by the client’s other advisors. For further discussion concerning
Circle’s brokerage practices, please see Item 12 below.

The fees and expenses imposed by mutual funds and ETFs are described in each fund’s prospectus
and will generally include a management fee, other fund expenses, and a possible distribution fee.
If hedge funds, private equity partnerships, fund of funds, and managed accounts also impose sales
charges, a client may pay an initial or deferred sales charge. The client should review both the fees
charged by the funds and the fees charged by Circle to fully understand the total amount of fees to
be paid by the client and to thereby evaluate the advisory services being provided.

Circle treats cash as an asset class. As such, unless determined to the contrary by Circle, all cash
positions (money markets, etc.) are included as part of assets under management for purposes of
calculating Circle’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), Circle may maintain cash positions for defensive purposes. In
addition, while assets are maintained in cash, such amounts could miss market advances.

Depending upon current yields, at any point in time, Circle’s advisory fee could exceed the interest
paid by the client’s money market fund.

Circle may price its services based upon various objective and subjective factors. Circle in its
discretion, may charge a lesser investment advisory fee, charge a flat fee, waive its fee entirely, or
charge a fee on a different interval, based upon certain criteria (i.e., anticipated future earning
capacity, anticipated future additional assets, dollar amount of assets to be managed, related
accounts, account composition, complexity of the engagement, anticipated services to be rendered,
grandfathered fee schedules, employees and family members, courtesy accounts, competition,
negotiations with client, etc.). Circle’s clients could pay diverse fees based upon the market value
of their assets, the complexity of the engagement, and the level and scope of the overall investment
advisory and/or consulting services to be rendered. As a result of these factors, similarly situated
clients could pay diverse fees, and the services provided by Circle to any particular client could be
available from other advisers at lower fees. All clients and prospective clients should be guided
accordingly.
Circle does not participate in a wrap fee program.

Item 7: Types of Clients

Our client base is comprised of a select group of high-net-worth individuals, multi-generational
families (80% of which are women-led), their related trusts and foundations, as well as independent
endowments.

Although we typically require $50 million in investment assets, the determining factor in
establishing a relationship with Circle is the client’s fit with our practice. Each client signs an
advisory agreement that sets forth the terms and conditions of the relationship between the client
and Circle as well as the fees.