Cruden Bay Investment Management LLC

Item 5 Fees and Compensation
Portfolio Management Services/Wrap Fee Program
Our annual fee for portfolio management services under the wrap fee program ranges up to 2.00% of
the market value of your assets under our management. Assets in each of your account(s) are
included in the fee assessment unless specifically identified in writing for exclusion. Our annual
portfolio management fee is billed and payable quarterly in advance based on the account balance at
the end of the billing period. If the portfolio management agreement is executed at any time other than
the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the
advisory fee is payable in proportion to the number of days in the quarter for which you are a
client. The specific fees payable to our firm will be clearly set forth in the management agreement you
sign with our firm.

You may terminate the portfolio management agreement upon written notice to our firm. You will incur
a pro rata charge for services rendered prior to the termination of the portfolio management
agreement, which means you will incur advisory fees only in proportion to the number of days in the
quarter for which you are a client. If you have pre-paid advisory fees that we have not yet earned, you
will receive a prorated refund of those fees.

You may be required to sign an agreement directly with the recommended third party adviser. You may
terminate your advisory relationship with the third party adviser according to the terms of your
agreement with the third party adviser. You should review each third party adviser's brochure for
specific information on how you may terminate your advisory relationship with the third party adviser.
You should contact the third party adviser directly for questions regarding your advisory agreement
with the third party adviser.

Consulting Services
Our consulting services, if offered, are provided as part of our portfolio management fee. No additional
fee applies to this service.

Financial Planning Services
We charge a fixed fee for financial planning services, which ranges up to $15,000 depending upon the
complexity and scope of the plan, your financial situation, and your objectives. Fees are payable as
invoiced. We do not require you to pay fees six or more months in advance. Should the engagement
last longer than six months between acceptance of financial planning agreement and delivery of the
financial plan, any prepaid unearned fees will be promptly returned to you less a pro rata charge for
bona fide financial planning services rendered to date.

With respect to clients who have engaged us for portfolio management services, our financial planning
services are also provided at no additional cost to clients and are only offered to existing portfolio
management clients.

Additional Fees and Expenses
The wrap fee program includes the costs of brokerage commissions for transactions executed through
LPL Financial, LLC, member FINRA/SIPC, an unaffiliated broker-dealer/custodian and registered
investment adviser ("LPL") (or a broker-dealer designated by LPL) or the Schwab Advisor Services
division of Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer, member SIPC. The wrap
fee program also includes charges relating to the settlement, clearance, or custody of securities in the
account. The wrap fee program fee does not include mark-ups and mark-downs, dealer spreads or
other costs associated with the purchase or sale of securities, interest, taxes, or other costs, such as
national securities exchange fees, charges for transactions not executed through LPL or Schwab,
costs associated with exchanging currencies, wire transfer fees, or other fees required by law or

imposed by third parties. The account will be responsible for these additional fees and expenses. The
wrap program fees that you pay to our firm for portfolio management services are separate and distinct
from the fees and expenses charged by mutual funds or exchange traded funds (described in each
fund's prospectus) to their shareholders. These fees will generally include a management fee and
other fund expenses. To fully understand the total cost you will incur, you should review all the fees
charged by mutual funds, exchange traded funds, our firm, and others.

We may trade client accounts on margin. Each client must sign a separate margin agreement before
margin is extended to that client account. Fees for advice and execution on these securities are based
on the total asset value of the account, which includes the value of the securities purchased on margin.
While a negative amount may show on a client's statement for the margined security as the result of a
lower net market value, the amount of the fee is based on the absolute market value. This creates a
conflict of interest where we have an incentive to encourage the use of margin to create a higher
market value and therefore receive a higher fee. The use of margin may also result in interest charges
in addition to all other fees and expenses associated with the security involved.

Compensation for the Sale of Investment Products
Some individuals providing investment advice on behalf of our firm are licensed as independent
insurance agents. These persons will earn commission-based compensation for selling insurance
products, including insurance products they sell to you. Insurance commissions earned by these
persons are separate and in addition to our advisory fees. This practice presents a conflict of interest
because persons providing investment advice on behalf of our firm who are insurance agents have an
incentive to recommend insurance products to you for the purpose of generating commissions rather
than solely based on your needs. You are under no obligation, contractually or otherwise, to purchase
insurance products through any person affiliated with our firm.

IRA Rollover Considerations
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Item 7 Types of Clients
We offer investment advisory services to individuals, high net worth individuals, foundations,
corporations, and other business entities.

In general, we require a minimum of $5,000,000 to open and maintain an advisory account. At our
discretion, we may waive this minimum account size.