First Georgetown Securities Inc

Item 5: Fees and Compensation
First Georgetown charges a management fee of ¾ of 1% per annum of total assets
under management (“AUM”). Management fees are directly debited from the client
accounts. Management fees are collected quarterly in advance based on the value of
total AUM as of 90 days after the prior billing period. The fee is negotiable. The fee
is based on the prior business day account(s) value as determined by our clearing firm,
multiplied by the annual fee percentage, and then divided by four.

In addition to their advisory duties, certain individuals associated with First Georgetown
are separately licensed as registered representatives of First Georgetown. Where their
activities extend to the purchase and/or sale of securities products, these individuals
receive commission-based compensation. Clients are charged commissions at fifty
percent (50%) of the firm’s regular commission rates, subject to a minimum twenty five
dollar ($25) commission per trade. This practice presents a conflict of interest and gives
the First Georgetown individuals who are licensed an incentive to recommend investment
products based on the compensation received rather than the client's needs. In addition to
disclosing these conflicts in this brochure, First Georgetown also reduces the commission
rates as described above, to reduce the incentive.

Form ADV Part 2A/2B: Investment Adviser Brochure and Brochure Supplements           Page 3
First Georgetown Securities, Inc.

Where clients may incur additional expense from brokerage-based activities, clients
should be aware that all custodial and execution fees remain separate and distinct from
those fees charged by First Georgetown for its asset management services. Clients should
note that the firm and its representatives may receive additional compensation in the form
of commissions and 12b-1 distribution fees from the respective mutual fund investment
made through First Georgetown.

All fees paid to First Georgetown for investment advisory services are separate and
distinct from the fees and expenses charged by mutual funds to their shareholders who
are our clients. These fees and expenses are described in each fund's prospectus. Fees will
generally include a management fee, other fund expenses, and a possible distribution fee.
If the fund also imposes sales charges, a client may pay an initial or deferred salescharge.

However, First Georgetown strives, whenever possible, to use only no-load mutual funds
for its advisory clients.

Accordingly, clients should review both the fees charged by the mutual funds and the
advisory fees charged by First Georgetown to fully appreciate the total amount of fees to
be paid by the client.

First Georgetown and/or the client may terminate the account agreement, in whole or in
part, at any time. Upon termination, any fees paid in advance will be prorated to the date
of termination and any excess shall be refunded to the client. The client’s advisory
agreement with First Georgetown is non-transferable without the client’s written
approval.

Item 7: Types of Clients
First Georgetown provides investment advisory services primarily to individuals.

First Georgetown requires clients to maintain a minimum account size of $250,000. This
minimum account size remains negotiable, under certain circumstances, and at the sole
discretion of the firm.

Form ADV Part 2A/2B: Investment Adviser Brochure and Brochure Supplements            Page 4
First Georgetown Securities, Inc.