Empirical Financial Services LLC

Item 5 – Fees and Compensation (Continued)

Other Fees Charged
Additional fees may apply to all clients. These fees are your responsibility and are separate from, and in addition
to, Empirical’s fees. Such fees may include, but are not limited to: custodial fees, debit balances, related margin
interest, IRA and retirement plan fees, transfer fees, SEC fees, fees embedded in money market funds or mutual
funds, wire transfer fees, overnight check fees, account closing fees, paper statement delivery fees, non-standard
asset fees, insufficient fund fees, returned check fees, transaction charges for fund level asset allocation model
trades, expenses charged by mutual funds (including management fees, transaction charges incurred for fund-
level asset allocation model trades, custody of fund assets and other fund expenses), expenses charged by variable
annuities and exchange-traded funds, or other fees or taxes that are required by law. Empirical may reimburse
clients for certain fees or charges that are not due to the client’s actions. Underlying fees can vary between
investments and are generally deducted directly from invested assets. Further information on these fees can be
found in the prospectuses of the underlying funds.

We endeavor to use investment products with the most competitive internal expenses and custodians with
competitive pricing and services. Item 12 – Brokerage Practices of this Brochure further describes the factors that
we consider in selecting or recommending broker-dealers for client transactions and determining the
reasonableness of their compensation (e.g., commissions).

Pooled Investment Vehicle – Empirical Alternative Income Fund, LP
In consideration for Empirical’s role as Investment Manager to the Empirical Alternative Income Fund (“Fund”),
Empirical is entitled to receive management fees from the Fund, and may receive performance allocations, with
respect to the Fund. The fees and compensation applicable to the Fund are described in detail in the applicable
governing documents, side letters and/or fee agreements. A potential investor should read and review all
governing documents in their entirety before making any investment decisions.

Associated operating expenses (“Operating Expenses”) of the Fund include, but are not limited to, fees paid to the
General Partner and Empirical, reimbursements to the General Partners for costs incurred in connection with
regulatory and compliance requirements, vendor monitoring, reporting services, state registrations, fees paid to
affiliates for fund administration, legal fees, accounting expenses, and state and federal taxes.
The Fund pays Empirical a fee (the “Management Fee”) as compensation for services rendered in the management
of the Fund. The Management Fee is calculated by multiplying (i) 0.375% (1.50% per annum) of each Limited
Partner’s Capital Account, all as of the last Business Day of the previous Fiscal Quarter. An administrative fee
(“Admin Fee”) is paid to the General Partner, or its affiliates, on a quarterly basis in advance as compensation for
services rendered in connection with the administration of the Fund and the management of its records.

Additionally, the Fund may have advanced expenses incurred in connection with organization of the Fund and
this Offering of Interests (excluding commissions), including legal fees, regulatory and compliance expenses, and
related accounting fees and printing costs (the “Organizational Expenses”) and all expenses incurred in
connection with the commencement of operations and other related out-of-pocket expenses (the “Start-up
Expenses”). The Fund will reimburse the appropriate party for any of these Organizational Expenses and Start-
up Expenses. The Fund intends that the Organizational Expenses and Start-up Expenses will be amortized and
charged to the Limited Partners’ Capital Accounts in equal monthly installments over a period of sixty (60)
months commencing from the Initial Closing Date.

Although GAAP normally requires that organizational costs be treated as an expense when incurred, the General
Partner believes that both (i) the impact on the Partnership’s results from this departure from GAAP will result
in a fairer apportionment of such expenses among Limited Partners, and (ii) this departure from GAAP is likely to
be deemed immaterial by the Partnership’s accountants and the Partnership anticipates receiving an unqualified
audit opinion from its auditors. If the Partnership is unexpectedly terminated within 60 months of the Initial
Closing Date or does not receive concurrence from its auditor any unamortized expenses will be recognized. The
General Partner may modify the time period over which the amounts are expensed for accounting purposes as it
deems fit, but only to the extent consistent with GAAP and its accountant’s recommendations.

                            Part 2A of Form ADV - Empirical Wealth Management

Item 7 – Types of Clients

We provide investment advice to:

  •    Individuals (including EWM employees)
  •    High net worth individuals
  •    Pensions and profit-sharing plans
  •    Charitable organizations
  •    Corporations or business entities
  •    Trusts
  •    Estates
  •    A pooled investment vehicle – Private Fund
In general, we require a minimum of $3,000,000 to open and maintain an investment advisory account, although
it is at our discretion to waive the minimum account size and the minimum fee.

The Alternative Income Fund limits its offerings to accredited investors. Under Rule 501 of Regulation D (“Rule
501”), an individual is an accredited investor if he or she: (i) has a net worth (along with his or her spouse) that
exceeds $1,000,000 (excluding the value of his or her primary residence); or (ii) income in excess of $200,000 (or
joint income in excess of $300,000 with spouse) in each of the two most recent years with a reasonable
expectation of reaching the same income level in the current year. An entity is an accredited investor if it: (i) is
owned exclusively by accredited investors; or (ii) is not formed for the specific purpose of acquiring interest in
the fund and has total assets in excess of $5,000,000. Generally, investors are allowed to self-certify as accredited
investors, and a private fund manager will be permitted to rely on an investor’s representation that he or she
meets the requirements without any further documentation.