Element Pointe Advisors LLC

Item 5. Fees and Compensation
We offer services on a fixed and/or asset-based fee basis which is determined by the client’s assets under management
and/or advisement.

Occasionally, clients ask us to report on assets we do not manage. In such cases, and in our sole discretion, we can negotiat e
a fixed reporting fee or, alternatively, charge an asset-based reporting fee determined by the value of the assets on which we
provide reporting services. This reporting fee generally does not exceed 0.20% of the value of the non-managed assets for
which we are asked to provide reporting services.

Investment Management and Family Office Advisory Fees

We offer services for an annual fee based on the amount of assets under our management. This management fee is set forth
in the client’s wealth management agreement and varies in accordance with the following blended (weighted average) fee
schedule:

                                     PORTFOLIO VALUE                           ANNUAL FEE
                                        First $3,000,000                           1.00%
                                        Next $7,000,000                            0.85%
                                        Next $15,000,000                           0.65%
                                        Next $25,000,000                           0.45%
                                       Next $50,000,000                            0.40%
                                      Above $100,000,000                           0.25%

Our fee for family office advisory services is determined on a case-by-case basis that typically depends on our
assessment of the scope of work, complexity of the engagement, overall relationship size, and potential for future
revenue. In some instances, we may choose to provide family office services for no additional fee beyond the fee paid
to us for investment management services. This practice creates a conflict of interest because some family office clients
will pay more than other clients will for our services. To mitigate this conflict, we make clients aware of this conflict
herein to assure they are aware of this conflict prior to engagement of our services.
Alternatively, we charge a negotiated fixed fee that is based upon the anticipated services and assets managed for a
particular client. Notwithstanding the standard fee schedule shown above, the fees we charge for our services are negotiable
at our sole discretion, and arrangements to charge a lesser fee can cause a client’s fee to differ from the fee charged to others,
as explained further in the section below titled “Fee Discretion.”

We prorate the annual fee and charge it quarterly, in arrears, based upon the market value of the average daily account balance
for each day of that quarter, including accrued interest and dividends. Since the asset-based fee is determined by the
average daily account balance, assets that are deposited into or withdrawn from an account after the inception of a
quarter (and for assets managed in the initial quarter), are billed on a pro rata basis. Advisory fees on investments in
hedge funds and private equity funds held in or reflected on the statements of brokerage custodians we recommend will be
billed quarterly, in arrears, based on the average daily value, in accordance with the valuation methodology outlined
below in the section titled “Valuation of Private Funds for Fee Billing.”

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Form ADV Part 2A –Brochure

For Held Away Assets, which includes private fund positions held in, or reflected on the statements of, custodial brokerage
accounts outside of brokerage custodians we recommend, we will charge an annual fee (which is pro - rated and billed
quarterly, based on a 360-day calendar, and charged in advance) based upon the value of the assets in the account at the
close of business on the last day of the previous quarter. Upon termination of an account holding Held Away Assets, we refund prepaid
fees due to the client on a prorated share based on the remaining days of the 90-day period.

Independent Managers typically charge additional fees pursuant to such relationship and clients should refer directly to the
disclosure document provided by the Independent Manager for its standard fee schedule.

Account Value Calculation for Fee Billing

Through our account aggregation and portfolio accounting software provider, we receive a data feed from each custodian,
which includes daily positions, transactions, and asset values. The value we use to calculate advisory fees can differ from the
net value shown on the brokerage statement the custodian of a client’s assets provides. There are two primary reasons for
these values to differ:

    1)      Trade Date versus Settlement Date – The brokerage statements most custodians provide value all securities and cash
            balances based upon trades not being completed until settlement date (when the money is due), while the value we
            use for billing is derived from our account aggregation and portfolio accounting software, which values all securities
            and cash balances based upon trade date (initiation of cost basis for performance and tax reporting purposes). For
            example, if a recent buy in an account has executed, but not yet settled at quarter-end, the trade will still show as a
            cash position on the brokerage statement the custodian provides. In contrast we will use the purchased security and
            value for performance and billing calculations.

    2)      Accrued Interest and Dividends – We include accrued interest and dividends in calculating the daily value of assets in
            accounts on which we serve as advisor. This may differ from the value reflected in statements the custodian provides,
            as most custodians do not include the value of accrued interest and dividends; rather, most custodians use a cash
...

Item 7. Types of Clients

We offer services to individuals, trusts, estates, charitable organizations, corporations, business entities, trustees or other er
fiduciaries to retirement plans subject to ERISA, and private funds organized by our affiliate.

When we provide investment advice to you regarding your retirement plan or individual retirement account, we are fiduciaries
within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with retirement clients’ interests, so we operate under a special rule
that requires us to act in retirement clients’ best interests and not put our interest ahead of them.

Under this regulation’s provisions, we must:

    •    Meet a professional standard of care when making investment recommendations (give prudent advice);
    •    Not put our financial interests ahead of a retirement client’s when making recommendations (give loyal advice);
    •    Avoid misleading statements about conflicts of interest, fees, and investments;
    •    Follow policies and procedures designed to ensure that we give advice that is in a retirement client’s best interest;
    •    Charge no more than is reasonable for our services; and
    •    Give a retirement client basic information about conflicts of interest.

We have an economic incentive to encourage a client to roll over a retirement plan or IRA into an IRA we manage. This
arrangement creates a conflict of interest in that it creates an incentive for us to recommend that a client roll over their account
for advisory services rather than retaining it with an unaffiliated third party. For this reason, as a matter of policy, we do not
solicit retirement account relationships. The retirement accounts that we manage are limited to those where a client for whom
we are managing other non-retirement accounts specifically requests to move their retirement account to us for the purpose
of consolidating providers, and where we agree to accommodate the client’s request.

Minimum Account Value

As a condition for starting and maintaining an investment management relationship, we impose a minimum portfolio value of
$15,000,000. In our sole discretion, we can accept clients with smaller portfolios based upon criteria, including, but not limited
to, anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related
accounts, account composition, pre-existing client, account retention, and pro bono activities. We only accept clients with less
than the minimum portfolio size if we determine the smaller portfolio size will not cause a substantial increase of investmen t
risk beyond the client’s identified risk tolerance. For certain client relationships and at our discretion, we aggregate the
portfolios of family members to meet the minimum portfolio size for the relationship.

Client investors in an affiliated private fund must meet the investment requirements set forth in the affiliated private fund ’s
offering documents.

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Form ADV Part 2A –Brochure