Graham Capital Wealth Management LLC

Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
agreement with the Advisor.

A. Fees for Advisory Services
Wealth Management Services
Wealth management fees are paid quarterly, at the end of each calendar quarter, pursuant to the terms of the
agreement. Wealth management fees are based on the market value of assets under management at the end of
the calendar quarter. Each Client will generally pay a wealth management fee of up to 1.75% annually based on
several factors, including the complexity of the services to be provided, the level of assets to be managed, and the
overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements,
portfolio restrictions, and other complexities may be charged a higher fee.

The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to
the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take
into consideration the aggregate assets under management with the Advisor. All securities held in accounts
managed by Graham will be independently valued by the Custodian. Graham will conduct periodic reviews of the
Custodian’s valuations.

The Advisor’s fee is exclusive of and in addition to any applicable securities transaction and custody fees, and
other related costs and expenses described in Item 5.C. below, which may be incurred by the Client. However, the
Advisor shall not receive any portion of these commissions, fees, and costs.

B. Fee Billing
Wealth Management Services
Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s]
at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be
deducted from the Client’s account[s] at the respective quarter end date. The amount due is calculated by applying
the quarterly rate (annual rate divided by 4) to the total assets under management with Graham at the end of each
quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting the deduction of
the wealth management fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the
Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written
authorization permitting advisory fees to be deducted by Graham directly from their account[s] held by the
Custodian as part of the wealth management agreement and separate account forms provided by the Custodian.

C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties other than Graham in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities
execution fees charged by the Custodian, as applicable. The Advisor’s recommended Custodian does not
charge securities transaction fees for ETF and equity trades in Client accounts but typically charges for mutual

                                        Graham Capital Wealth Management, LLC
                                1120 Connecticut Ave. NW, Suite 1021, Washington, DC 20036
                                       Phone: (202) 780-7726 | Fax: (202) 836-7732
                                               www.grahamcapitalwealth.com

funds and other types of investments. The fees charged by Graham are separate and distinct from these
custody and execution fees.

In addition, all fees paid to Graham for investment advisory services are separate and distinct from the
expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are
described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees
for the funds, other fund expenses, account administration (e.g., custody, brokerage, and account reporting),
and a possible distribution fee. A Client may be able to invest in these products directly, without the services of
Graham, but would not receive the services provided by Graham which are designed, among other things, to
assist the Client in determining which products or services are most appropriate for each Client’s financial
situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees
charged by Graham to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices
for additional information.

D. Advance Payment of Fees and Termination
Wealth Management Services
Graham is compensated for its wealth management services at the end of the quarter after services are rendered.
Either party may terminate the wealth management agreement, at any time, by providing advance written notice to
the other party. The Client may also terminate the wealth management agreement within five (5) business days of
signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for
bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the
Client. The Client’s wealth management agreement with the Advisor is non-transferable without the Client’s prior
consent.

E. Compensation for Sales of Securities
Graham does not buy or sell securities to earn commissions and does not receive any compensation for
securities transactions in any Client account other than the investment advisory fees noted above.

Graham Capital Advisors, LLC
Certain Advisory Persons are also licensed as independent insurance professionals of Graham Capital
Advisors, LLC (“Graham Capital Advisors”), an insurance agency under common control with Graham Capital
...

Item 7 – Types of Clients
Graham offers investment advisory services to individuals, high net worth individuals, trusts, and estates, and
corporations. The amount of each type of Client is available on Graham’s Form ADV Part 1A. These amounts
may change over time and are updated at least annually by the Advisor.

Graham generally requires a minimum relationship size of $40,000, which may be reduced at the sole discretion
of the Advisor.
                                        Graham Capital Wealth Management, LLC
                                1120 Connecticut Ave. NW, Suite 1021, Washington, DC 20036
                                       Phone: (202) 780-7726 | Fax: (202) 836-7732
                                               www.grahamcapitalwealth.com