Gem Asset Management LLC

Item 5 – Fees and Compensation

       We clarified that our advisory fees apply to assets in held-away accounts and to assets
managed by Independent Managers. We added detailed disclosure regarding the fees charged by
Independent Managers, including model-based fee schedules, tiered pricing, and a collateral
management fee of up to 0.15% annually.

        We also updated our financial planning fee disclosure to clarify that planning fees may be
credited if a client later engages us for investment management services. In addition, we
enhanced our disclosure regarding billing practices, including direct fee deduction, the potential
liquidation of assets to pay fees, and billing procedures for held-away accounts.

Item 7 – Types of Clients

       We provide investment management services to individuals, high net worth individuals,
pension and profit sharing plans, charitable institutions, and foundations. We do not have a
minimum account size.