Fitzwilliams Wealth Management Inc

Item 5: Fees and Compensation

        FINANCIAL PLANNING

        FWM’s financial planning fees are included in FWM’s investment management fees.

        INVESTMENT MANAGEMENT
        FWM’s annual fee schedule for our investment management services is as follows:

                       Account Value                                         Annual Fee Rate

                       $0 - $2,500,000                                             2.00%

                    $2,500,001 - $5,000,000                                        1.50%

                  $5,000,001 - $10,000,000                                         1.00%

                  All Assets over $10,000,000                                      0.80%

       Our minimum account size, which is negotiable, is $100,000. This fee schedule is not negotiable
       though FWM does reserve the right to reduce fees for special circumstances at our own discretion.
       Special circumstances might include exceptionally large accounts as well as those for employees
       and family members. Our fee is billed monthly in arrears based upon average daily balance. When
       an account is opened during a month, that month’s prorated fee is charged in arrears based on
       average daily balance. Please note that it is the client’s responsibility to verify the accuracy of the
       fee charged for the period.
       If a client decides to cancel within the first five business days after signing the advisory agreement,
       then any asset management fees paid to us will be refunded in full. After the initial five-day period,
       upon final termination of the agreement, the client will be provided a pro-rata refund of fees paid
       based on the number of days the assets were under our management. FWM must receive notice from
       the client in writing in order to determine the date of cancellation.
       Clients pay their fees to FWM by directing the custodian to allow FWM to deduct its fees directly
       from their investment account(s). Invoice will itemize the fees charged. Additionally, clients may
       instruct FWM to deduct all of the fees from one or more specific accounts. Even though FWM uses
       a Sub-Advisor to manage investment accounts, no additional fees will be charged to the client by
       the Sub-Advisor. Total advisory fees charged to clients will not exceed 2% of the assets under
       management when a Sub-Advisor is utilized.

       OTHER FEES
       In addition to the asset management fees charged by FWM, clients will incur custodian fees,
       mutual fund expenses, and other brokerage costs including trading commissions. Client accounts
       pay directly for the fees assessed by the custodian, such as transaction, wire, exchange, or
       custodial fees. FWM will do its best to avoid and/or minimize the impact of any such fees because
       the firm recognizes that fees erode the performance of a client’s investment accounts. FWM
       does not benefit directly from these fees. For more information on the custodial relationship,
       please refer to the section below “Brokerage Practices” for more details.

       Fees must be disclosed that are based on performance (such as a share of the capital gains or
       capital appreciation) or side-by-side management (which is when some clients pay fees based on
       performance while others do not).

Item 7: Types of Clients
         FWM provides investment advisory services to:

             •   Individuals
             •   High net worth individuals
             •   Pension and profit-sharing plans
             •   Trusts, estates, or charitable organizations
             •   Corporations and other businesses
         FWM typically requires a minimum account size of $100,000 for investment management
         services. However, FWM may accept smaller accounts based upon special circumstances, at its
         own discretion. For example, FWM may accept a smaller account for a family member of an
         existing client.