CIRO Capital LLC

Item 5: Fees & Compensation

Compensation for Our Advisory Services

Comprehensive Portfolio Management:

Pursuant to an investment advisory contract signed by each client, the client will pay our firm an annual
management fee billed quarterly in advance based on the value of the account(s) on the last day of
the previous quarter. New account fees will be prorated from the inception of the account to the end of
the first quarter. The management fee will range up to 2.00% per annum depending on the type and
complexity of the investment management strategy employed as well as the size of the account or overall
client relationship. Fees are negotiable and will be deducted from client account(s). The negotiated
annual fee will be applied to the total value of the account. Asset management fees will be directly
deducted from the client account on a quarterly basis by the qualified custodian. The client will give
written authorization permitting the Advisor to be paid directly from their account held by the custodian.
The custodian will send a statement at least quarterly to the client and the Advisor will also send an invoice
to the client outlining the fee calculation and time period covered, and the amount withdrawn from the
client account each time the fee deduction invoice is sent to the qualified custodian. Where it is not
practical to deduct fees directly from client accounts, client will be sent an invoice at the beginning of each
quarter. The invoice is payable upon receipt. In rare cases, our firm will agree to directly invoice.

The third party money managers we recommend will not directly charge you a higher fee than they
would have charged without us introducing you to them. Third party money managers establish
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and maintain their own separate billing processes over which we have no control. In general, they
will directly bill you and describe how this works in their separate written disclosure documents.
The maximum annual fees charged to clients including our fee and that of the third party money
managers will not exceed 2.00% per annum. Our comprehensive portfolio management services
always include the use of third party money managers. Assuming an account with $1 million in
assets, and a negotiated annual fee of 1.50%, our quarterly fee is calculated as follows: $1 million
X (1.50%/4) = $1 million X 0.375% = $3,750.

Financial Planning & Consulting:

Our firm charges on an hourly basis for financial planning and consulting services. The total
estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our
engagement with the client. Financial planning clients will be provided with the estimated hours
on which the fee is based. The maximum hourly fee to be charged will not exceed $500. The fee-
paying arrangements will be determined on a case-by-case basis and will be detailed in the signed
consulting agreement. Our firm’s financial planning services generally require a minimum of two
hours and a maximum of seven hours. Our firm does not require the prepayment of fees of more
than $500 per client and for six months or more in advance.

Representatives of Ciro Capital may be insurance agents for which they receive normal and
customary commissions. Financial planning clients are under no obligation to act on the
recommendations of Ciro Capital or its investment advisor representatives. If clients wish to act
on insurance recommendations, the client is free to implement the recommendations through
insurance companies of their choice.

Retirement Plan Consulting:

Our Retirement Plan Consulting services are billed on a fee based on the percentage of Plan assets
under management. The total estimated fee, as well as the ultimate fee charged, is based on the
scope and complexity of our engagement with the client. Retirement plan consulting fees based
on a percentage of managed Plan assets will not exceed 1.00%. This fee is in addition to the annual
management fee. The fee-paying arrangements will be determined on a case-by-case basis and
will be detailed in the signed consulting agreement. Clients that engage our firm for
comprehensive portfolio management, including third party money managers, and retirement plan
consulting, will never pay more the 2.00% per annum in management and retirement plan
consulting fees, including the fees of the third party money manager.

Pursuant to the California Code of Regulations Subsection (j) of Rule 260.238, Advisor discloses that the
Client may receive lower fees from other sources for comparable services.

Other Types of Fees & Expenses

Clients will incur transaction fees for trades executed by their chosen custodian, either based on a
percentage of the dollar amount of assets in the account(s) or via individual transaction charges. These
transaction fees are separate from our firm’s advisory fees and will be disclosed by the chosen
custodian. Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction fees for U.S. listed
equities and exchange traded funds.

Clients may also pay holdings charges imposed by the chosen custodian for certain investments,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), distribution fees,
surrender charges, variable annuity fees, IRA and qualified retirement plan fees, mark-ups and mark-
downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer
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fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not
receive a portion of these fees.

Termination & Refunds
...

Item 7: Types of Clients & Account Requirements

Our firm has the following types of clients:
   • Individuals and High Net Worth Individuals;
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     •    Trusts, Estates or Charitable Organizations;
     •    401(k), Pension, Profit Sharing and Cash Balance Plans;
     •    Small Business Owners and Professional Practices; and
     •    Corporations, Limited Liability Companies and/or Other Business Types.

Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging
us.