Gibbs Wealth Management LLC

Item 5: Fees and Compensation
Advisory Fees
Gibbs charges an annual asset-based advisory fee for discre onary por olio management
services provided through the Advisor-Directed Model Management program sponsored by OPS
and Orion OCIO. The advisory fee is expressed as a percentage of the market value of the assets
under management and is disclosed in the client’s advisory agreement.

Total fees to the client—including Gibbs’s advisory fee, pla orm fees, and Strategist or model
management fees—will not exceed 3% of assets under management per year.

Fees may be nego able based on factors such as account size, services requested, householding,
and the overall rela onship with Gibbs.

Advisory fees are typically billed quarterly in advance based on the account value as of the last
business day of the prior quarter. Fees are generally deducted directly from client accounts by the
custodian upon wri en authoriza on from the client.

If a client ini ates or terminates services during a billing period, the fee will be prorated based on
the number of days services were provided. Any unearned fees paid in advance will be refunded
on a prorated basis.

Billing Methods
Fees are deducted directly from a designated client account. Clients must provide advance wri en
authoriza on for direct debi ng of their investment account. Addi onal informa on regarding
fee deduc on and custody is provided in Item 15 of this Brochure.

Other Fees and Expenses
Orion OCIO
Orion OCIO provides Model Por olios and investment management services through the
Advisor-Directed Model Management program. Orion OCIO charges a separate investment
management fee, which is exclusive of and in addi on to Gibbs’s advisory fee. Orion OCIO does
not receive any por on of the advisory fee charged by Gibbs.

Orion OCIO fees are billed quarterly in advance based on the prior quarter-end balance and are
prorated for accounts opened or closed mid-billing period.

Gibbs receives a por on of Orion OCIO’s investment management fee under a revenue-sharing
arrangement. This creates a conflict of interest because Gibbs has an incen ve to recommend or
maintain client assets in Orion OCIO strategies. This conflict is mi gated through full disclosure,
supervisory oversight, and Gibbs’s fiduciary obliga on to act in the client’s best interest.

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Orion OCIO Fee Schedule
          Strategy                     Management Fee                  Management Fee
                                     (Households between               (Households over
                                       $0mm and $3mm)                      $3mm)
         Partner SMAs                       0.70%                           0.65%
     TSC Global Conviction                  0.80%                           0.75%
     Custom Bond Ladders                    0.40%                           0.40%
            TSC BRIX                        0.35%                           0.30%
  TSC Asset Alloca on Models                0.35%                           0.30%
   TSC Brix Tac cal High Yield              0.45%                           0.40%
      TSC Trading Services                  0.30%                           0.30%
    Cash Management Bond                    0.30%                           0.30%
            Portfolio

Orion OCIO fees are in addi on to the Gibbs’s advisory fee and any custodial or transac on fees
charged by the custodian.

OPS
OPS provides pla orm administra on, technology, repor ng, and trade implementa on services.
OPS charges a pla orm administra on fee that is exclusive of and in addi on to Gibbs’s advisory
fee. OPS does not receive any por on of the advisory fee charged by Gibbs.

OPS fees are billed monthly in arrears based on the average daily balance of the prior month and
are prorated for accounts opened or closed mid-billing period.

Gibbs receives compensa on from OPS under a revenue-sharing arrangement based on assets
under management on the OPS pla orm. This creates a conflict of interest because Gibbs has an
incen ve to recommend or maintain client assets on the OPS pla orm. This conflict is mi gated
through disclosure, supervisory oversight, and Gibbs’s fiduciary duty.

OPS Fee Schedule – Exis ng Clients
                Account Size                                      Percentage
                 $0-$50,000                                         0.45%
             $50,000-$100,000                                       0.30%
             $100,000-$500,000                                      0.20%
            $500,000-$1,000,000                                     0.15%
            $1,000,000-5,000,000                                    0.10%
                $5,000,001+                                         0.08%

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OPS Fee Schedule – New Clients
                Account Size                                      Percentage
                $0-$100,000                                         0.35%
             $100,000-$250,000                                      0.30%
            $250,000-$1,000,000                                     0.20%
                $1,000,000+                                         0.00%

OPS fees are automa cally deducted from client accounts by OPS, and OPS remits Gibbs’s
por on of the fees.
ZEGA
ZEGA charges an annualized management fee of 0.45% of assets under management, calculated
based on the end-of-quarter account value. This fee is exclusive of, and in addi on to, Gibbs’s
advisory fee. ZEGA does not receive any por on of the advisory fee charged by Gibbs.

Fees charged by ZEGA may be higher than those charged by other investment advisers for
comparable services, and lower-cost alterna ves may be available. Fees are prorated for accounts
opened or closed mid-billing period.

Additional Client Fees and Expenses
Mutual Fund and Exchange-Traded Fund (“ETF”) Expenses
Investments in mutual funds and ETFs include internal management fees and opera ng expenses
...

Item 7: Types of Clients
Gibbs generally provides investment advisory services to individuals and high-net-worth
individuals. Client rela onships vary in scope, complexity, and dura on based on each client’s
financial situa on, investment objec ves, and overall needs.

Account Minimums
Gibbs generally requires a minimum of $25,000 to open and maintain an account on the
investment pla orms used by the firm. This minimum is based on the requirements of the
third-party pla orms and custodians u lized for client accounts.

Gibbs may, in its sole discre on, accept accounts with lesser assets when doing so is consistent
with the client’s needs and Gibbs’s service model.

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