Embree Financial Group

Fees and Compensation
EMBREE FINANCIAL Group bases its fees on a percentage of assets under management, hourly charges
and/or fixed fees (not including subscription fees). Financial plans are priced according to the degree of
complexity associated with the client’s situation and amount of time required to service the client in a high-
quality manner. Although most commissions are fixed, ongoing management fees are NEGOTIABLE based
on factors highlighted above. Investment management fees are billed quarterly, in ADVANCE, and fees are
deducted at the beginning of the three-month period for which the work is to be done. Fees are usually deducted
from designated client account(s) to facilitate billing. The client must consent in advance to a direct debit to
their investment account.

The maximum amount a client would be charged for advisory services is 1.5%.

Our fee schedule encompasses the broad scope of services and holistic approach provided by EMBREE
FINANCIAL Group. At times, the firm will charge extra for Financial Planning depending on the complexity
of the case and amount of time required to produce the desired output. Although a fee schedule is employed in
most cases, fees may be negotiated based on the level of services provided and amount of assets involved. In
some circumstances, a Retainer Agreement is executed in lieu of an Advisory Service Agreement when it is
more appropriate to work on a fixed-fee basis for a limited period of time. Fees for retainer services will
typically apply to Financial Planning Services and are NEGOTIABLE based on the complexity of the case.

Incentive Fees: In some cases, clients may request an incentive fee structure for their account. In such cases,
EMBREE FINANCIAL Group will provide the client with options and customize an incentive fee structure in
line with the client’s wishes. EMBREE FINANCIAL Group will only engage in an incentive fee relationship
with the client if the client meets the definition of a “qualified client” under the federal securities laws at the
time the relationship is entered.

Fees charged for Retirement Plan Services are customized for each plan and may vary depending on complexity
and level of services provided. Fees may be asset-based, paid entirely by participants, flat fee-based, paid by
plan sponsor, or a combination of the two. Most proposed fee schedules provide a menu of services available,
and allow the client to select how, and for what they choose to pay. Private Wealth Management fees are
typically debited from client accounts at the beginning of each quarter based upon the account balance on the
last day of the previous quarter. Management fees do not include transaction charges, which are charged by the
custodian and incurred by the client. EMBREE FINANCIAL Group, at its sole discretion, may waive its
minimum fee and/or charge a lesser investment advisory fee based upon certain criteria (e.g., historical
relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar
amounts of assets to be managed, related accounts, account composition, negotiations with clients, etc.).

                           Part 2A of Form ADV

Any Private Wealth client of EMBREE FINANCIAL Group who wishes to terminate service provided by the
Applicant may do so at any time. Written notification of the termination is requested but not required. Any
termination of managed accounts is subject to the quarterly fee, in effect at the time of cancellation. Clients
have the right to terminate the service contract without penalty within five (5) business days after entering into
this agreement. Custodians such as Charles Schwab or Fidelity may charge transaction fees on purchases or
sales of certain mutual funds and exchange-traded funds. These transaction charges are usually small and
incidental to the purchase or sale of a security. The selection of the security is more important than the nominal
fee that the custodian charges to buy or sell the security.

Mutual funds generally charge a management fee for their services as investment managers. The management
fee is called an expense ratio. For example, an expense ratio of 0.50 means that the mutual fund company
charges one half of one percent (0.5%) for their services. These fees are in addition to the advisory service fees
paid to EMBREE FINANCIAL Group. Performance figures quoted by mutual fund companies in various
publications are after their fees have been deducted.

EMBREE FINANCIAL Group reserves the right to stop work on any account that is more than 120 days
overdue. In addition, EMBREE FINANCIAL Group reserves the right to terminate any financial planning
engagement where a client has willfully or purposely concealed information relevant to their financial situation.
Fees charged by EMBREE FINANCIAL Group are typically asset-based, not performance-based, because
clients are better served with this structure. In a rare case where a client prefers a performance- based structure,
such an arrangement will be negotiated directly and properly documented.

In cases where EMBREE FINANCIAL Group recommends a private placement and the client invests in such,
EMBREE FINANCIAL Group will charge a fee on those assets in one of two ways. If the investment is valued
quarterly and that value is available to EMBREE FINANCIAL Group, then the client will be billed on the
market value. In cases where quarterly market valuations are not available, then the client will be billed on the
amount of money committed to the private investment. In both cases, the details will be described in the fee
section of the EMBREE FINANCIAL Group client service agreement.

Certain representatives of EMBREE FINANCIAL Group are licensed insurance agents and, in such capacity,
may recommend, on a fully disclosed commission basis, the purchase of certain insurance products. This
practice presents a potential conflict of interest and may give EMBREE FINANCIAL Group or its
...

Types of Clients
EMBREE FINANCIAL Group generally provides investment advice to high-net-worth individuals, individuals
and families, retirement plans, pension and profit-sharing plans, trusts, estates, corporations, or business
entities.

Client relationships vary in scope and length of service. EMBREE FINANCIAL Group account minimums are
$500,000 of investible assets, which typically equates to an annual fee of $5,000, although in certain cases this
minimum is waived.

Methods of Analysis, Investment Strategies, and Risk of Loss
Investment and securities analysis includes fundamental analysis, technical analysis, and cyclical analysis.
Fundamental analysis is a method of equity analysis regarding a company’s underlying earnings, expenses,
assets, and liabilities. This value is then compared to the current price of the company’s security to determine
whether to purchase, sell or hold the security. Technical analysis is a form of statistical analysis surrounding
market activity, such as past prices and trading volumes. Technical analysis is not attempting to measure a
security’s current value, but instead it seeks to identify patterns that can predict future activity for that security.
Cyclical analysis is a form of fundamental analysis that bases investment decisions on the different stages of
an economic cycle and the potential strength of that industry at a given time.

EMBREE FINANCIAL Group employs numerous tools and sources to conduct these analyses, including
advanced performance metrics, corporate filings, performance modeling software, corporate rating services,
timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and
company press releases.

Additionally, investment opinions and positions are formed through the ongoing education, information
analysis, and unique market scrutiny of the EMBREE FINANCIAL Group team. The EMBREE FINANCIAL
Group team constantly evaluates the markets in a distinct fashion, producing inimitable data and outlooks
aimed at better serving the firm's clients.

Other sources include Morningstar, Charles Schwab & Company, Bloomberg and numerous other online
information providers. Assets are invested primarily in no-load mutual funds, exchange- traded funds and
individual securities. Additionally, when appropriate, EMBREE FINANCIAL Group will work with the client
to invest in limited partnerships for alternative investments such as hedge funds, private equity, and real estate.
Security types may include, but are not limited to, the following: equities (stocks), warrants, corporate debt
securities, commercial paper, certificates of deposit, municipal securities, investment company securities (i.e.,
mutual funds), U. S. government securities, corporate bonds, options contracts, futures contracts, and interests
in partnerships. Initial public offerings (IPOs) are not available through EMBREE FINANCIAL Group.

                          Part 2A of Form ADV

Clients should be advised that all investments involve risk of loss, which includes loss of principle and a
reduction in earnings. Additionally, investors face the following risks:

    •   Interest rate risk: Interest rate risk is the possibility that the value of a security or portfolio will change
        as interest rates change.
    •   Market risk: Market risk is the possibility of an investor experiencing losses due to factors that affect
        the overall performance of the financial markets.
    •   Inflation risk: Inflation risk is the possibility that money loses its purchasing power over time due to
        rising prices.
    •   Currency risk: Currency risk is the possibility of financial loss or gain due to changes in the value of
        one currency relative to another. It's also known as foreign exchange risk or exchange-rate risk.
    •   Reinvestment risk: Reinvestment risk is the risk that an investor will have to reinvest the coupon,
        principal and/or interest received from an investment at a potentially lower rate than they are currently
        receiving.
    •   Business risk: Business risk is the possibility of anything that could negatively impact a company's
        finances or operations.
    •   Liquidity risk: Liquidity risk is the risk that a market will not allow an investor to buy or sell securities
        at the desired time or price.
    •   Financial risk: Financial risk is any of various types of risk associated with financing, including
        financial transactions that include company loans in risk of default.
    •   Alternative investment risk: Alternative investments come with their own risks like potential lack of
        liquidity, complexity and transparency issues, and higher fees and costs.

EMBREE FINANCIAL Group manages each portfolio in a manner consistent with its appropriate level of risk,
as determined by the client.