Covingtonalsina LLC

Item 5: Fees and Compensation

A. Fee Schedule

Portfolio Management Fees

        Total Assets Under Management          Annual Fees
        $0 - $99,999                           1.25%

        $100,000 - $999,999                    1.00%

        $1,000,000 - $2,999,999                0.75%

        $3,000,000 - $4,999,999                0.35%

        $5,000,000 - AND UP                    0.15%

CovingtonAlsina uses the value of the account as of the last business day of the billing
period, after taking into account deposits and withdrawals, for purposes of determining
the market value of the assets upon which the advisory fee is based.

These fees are generally negotiable and the final fee schedule will be memorialized in the
client’s advisory agreement. Clients may terminate the agreement without penalty for a
full refund of CovingtonAlsina's fees within five business days of signing the Investment
Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract
immediately upon written notice.

Selection of Other Advisers /Use of Independent Managers

Clients will pay CovingtonAlsina its standard fee in addition to the standard fee for SEI
Private Trust. The fees will not exceed any limit imposed by any regulatory agency. These
fees are negotiable.

Pension Consulting Services Fees

The annual fee for retirement plan advisory services is up to 1% of the plan assets for
which CovingtonAlsina is providing such services. These fees are negotiable.

Financial Planning Fees

Fixed Fees
The negotiated fixed rate for creating client financial plans is between $500 and $5,000.

The fixed rate for Core Program Services is up to $1,250 annually. The fixed rate for Choice
Program Services is up to $5,250 annually. The final fee for these service packages is

determined based on the amount of portfolio management fees paid by the client to
CovingtonAlsina during the prior calendar year. Therefore, as a client’s prior-year
portfolio management fee increases, the service package fee will decrease.

Tax preparation services may be included as part of portfolio management or financial
planning fees, or they may be provided for an additional fee, which is separate from and
in addition to the firm’s investment advisory fees. When billed separately, the rate will be
a one-time fixed fee billed in arrears.

Hourly Fees
The negotiated hourly fee for these services is between $150 and $500.

Clients may terminate the agreement without penalty, for full refund of
CovingtonAlsina’s fees, within five business days of signing the Financial Planning
Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally
upon written notice.

B. Payment of Fees

Payment of Portfolio Management Fees

Asset-based portfolio management fees are withdrawn directly from the client's accounts
with client's written authorization on a quarterly or monthly basis. Fees are paid in
arrears.

Payment of Selection of Other Advisers /Use of Independent Managers
Fees

Fees for selection of SEI Private Trust as third-party adviser are withdrawn directly from
the client's accounts with client's written authorization. Fees are paid quarterly or monthly
in arrears.

Payment of Pension Consulting Services Fees

Pension consulting fees are withdrawn directly from the client’s accounts with client’s
written authorization or may be invoiced and billed directly to the client and clients may
select the method in which they are billed. Fees are paid quarterly.

Payment of Financial Planning Fees

Financial planning fees are paid via check or through a secure third-party processor via
ACH or credit card. Clients may also request financial planning fees to be directly
deducted from their advisory account by providing written consent.

       Fixed financial planning fees are paid 50-100% in advance, but never more than six
       months in advance, with the remainder due upon completion if not paid in full.

       Fixed fees for the Core and Choice Program Service packages are payable monthly, in
       advance.

       Hourly financial planning fees are paid in arrears upon completion.

       Payment of Educational Seminar/Workshop Fees

       Educational seminars and workshops are offered for a fee of up to $75 per session, payable
       in advance and non-refundable.

       C. Client Responsibility For Third Party Fees

       Clients are responsible for the payment of all third-party fees (i.e., custodian fees,
       brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
       distinct from the fees and expenses charged by CovingtonAlsina. Please see Item 12 of this
       brochure regarding broker-dealer/custodian.

       D. Prepayment of Fees

       CovingtonAlsina collects certain fees in advance and certain fees in arrears, as indicated
       above. Refunds for fees paid in advance but not yet earned will be refunded on a prorated
       basis and returned the client via check, or return deposit back into the client’s account.

       CovingtonAlsina does not collect asset-based fees in advance.

       Fixed fees that are collected in advance will be refunded based on the prorated amount of
       work completed at the point of termination.

       E. Outside Compensation For the Sale of Securities to Clients

       Neither CovingtonAlsina nor its supervised persons accept any compensation for the sale
       of investment products, including asset-based sales charges or service fees from the sale
       of mutual funds.

Item 7: Types of Clients

CovingtonAlsina generally provides advisory services to the following types of clients:

       ❖      Individuals
       ❖      High-Net-Worth Individuals
       ❖      Pension and profit-sharing plans

There is no account minimum for any of CovingtonAlsina’s services.