Guild Investment Management Inc

5.     Fees and Compensation for Guild Non-Farther Financial Platform Clients

Guild earns investment management fees based on a percentage of the net assets in the managed
accounts. The asset-based fees typically range from 0.50% of assets under management annually to
1.5% of the assets under management annually.

Fee arrangements can be negotiated. One of the factors that determines the fee schedule is the type of
portfolio management services provided. Guild classifies its accounts by the following portfolio
management styles:

       •       Global Growth
       •       Income / Total Return
       •       Hybrid (combination of Growth and Income)
       •       Wealth Builder Dividend Income

Other factors that can affect the fees are the custodial arrangements and the total assets under
management from related accounts.

Before clients enter into an investment management agreement with Guild, they are provided with a fee
schedule showing the proposed fee for their account. Management fees are payable either monthly or
quarterly in advance and asset-based fees are based on the net asset value of the account at the start of a
particular billing period.

Services may be terminated by the client by written notice to Guild. In the event of termination during
the billing period, management and administrative fees are prorated and the client receives a refund on
the unearned portion of the fee applicable to the days remaining between the termination date and the
end of the billing period.

Clients may elect to be billed directly for fees or authorize Guild to debit fees from clients’ accounts.

Guild’s management fees are exclusive of brokerage commissions, transaction fees, and other related
costs and expenses, which shall be incurred by the client. For example, clients may incur certain charges
imposed by custodians, brokers, and other third parties such as fees charged by other managers,
custodial fees, deferred sales charges, transfer taxes, wire transfer fees, electronic fund fees, and other
fees and taxes on brokerage accounts and securities transactions. Guild may at times invest client funds
in mutual funds and exchange traded funds, which also charge internal management fees. Such charges,
fees and commissions are paid by clients in addition to Guild’s fee. Guild does not receive any portion
of these third-party commissions, fees, and costs. Brokerage costs are described more fully in Item 12.

Management Fee Adjustments and Rebates for Additions and Withdrawals

For non-Farther platform accounts billed quarterly in advance, Guild calculates any billable adjustments
to management fees based on additions to the account and/or withdrawals from the account that exceed a
$20,000 threshold. Capital additions that come into the account subsequent to the billing valuation
constitute new capital being invested, so Guild will calculate the additional fee adjustments on the full

                                                        Guild Investment Management, Inc. ADV Part 2A - Brochure

value of any additions that exceed the $20,000 threshold. In the case of billable capital additions that
exceed $20,000, time-weighted calculations of fee adjustments will be added to subsequent management
billing fee calculations.

In the case of withdrawals that exceed $20,000, time-weighted calculated fee rebates will be deducted
from the subsequent period management fee quarterly billing calculations. These cash flow adjustment
calculations (if any) will be presented on management quarterly fee billings. The proposed $20,000
threshold is deemed fair on withdrawals as it represents a small dollar amount in most cases. For
example, in the case of a $20,000 withdrawal taking place only ten days into a 90-day billing period, the
rebate would be less than $50. In addition, smaller withdrawal amounts are often less than the net
appreciation and income of the account since the billing valuation date. In these cases, withdrawals
would be considered to be coming from income and appreciation before coming from the billable
account value at the beginning of the billing period.

Guild will not calculate adjustments to management fees for additions and withdrawals made mid-month
for accounts that are billed monthly in advance. This particularly applies to accounts on the Farther
platform, which have fees collected monthly in advance, per the Farther Investment Advisory
Agreement.

The following examples summarize the typical investment management and fee arrangements based on
the type of account:

Typical Global Growth managed account

For clients that prioritize growth and appreciation for their portfolio, Guild manages Global Growth
accounts. Guild employs strategies including concentrating investments from time to time, investing in
U.S. and foreign equity and debt securities including securities of companies in developing or emerging
markets, acquiring precious metals-related securities, currency trading, and hedging; however, for the
Global Growth accounts, Guild typically does not utilize leverage or borrowing, nor does Guild typically
engage in options trading.

Global Growth annual management fees can be tiered, such as 1.50% per annum on the first $1,000,000
of net asset value, and then 1.00% on the amounts exceeding the first $1,000,000 of portfolio value, or
they can be a fixed percent. The typical minimum annual fee for this type of account is $5,000; however,
fee minimums can be negotiated.

The annual management fee in the Guild Global Growth accounts will be billed in four quarterly
installments based on the net asset value of the portfolio. The initial management fee will be based on
the initial asset value of the account and will cover the fee for the period from the initial valuation date
to the last day of the third full month after Guild commences management of the account. Subsequent
management fee billings will occur each three-month period thereafter based on the net asset value on
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Types of Clients

Guild clients generally consist of U.S. and non-U.S. individuals, high net worth individuals, profit
sharing and pension plans, personal trusts, corporations, charitable institutions, and foundations.
Guild’s investment advisory and portfolio management services are tailored to clients’ goals and
objectives. Guild has one or more consultations with each client in an effort to determine the
individual account investment goals and objectives with respect to seeking capital preservation,
growth through capital gains, current income, or a combination thereof, as well as the risk tolerance
level, tax considerations, willingness for the account to be actively traded, and other considerations.

Guild manages portfolios categorized by style and objective and are often referred to as: Global

                                                       Guild Investment Management, Inc. ADV Part 2A - Brochure

Growth, Income/Total Return, Wealth Builder Dividend Income, and Hybrid portfolios.

Guild typically does not render advice on other investments such as real estate and insurance, which
may constitute part of a client’s total investment portfolio. Also, Guild does not generally invest in
securities of certain companies that derive a significant portion of their revenues from activities that
may be considered socially objectionable, such as weapons, tobacco, alcohol, and gambling.

Clients may impose restrictions on the kind of investments made by Guild for their accounts. For
example, clients may desire to have certain industries or companies excluded from their portfolio.
Investment guidelines and restrictions must be provided to Guild in writing. Subject to such
restrictions, if any, for discretionary accounts under management, Guild has authority, without
obtaining the advance consent of the client, to determine which securities are to be bought or sold, the
total amount of securities bought or sold, and the brokerage commission rates to be paid.

In addition to restrictions placed by clients, clients may also request or suggest that Guild buy or sell
positions in their accounts managed by Guild. Guild will act on clients’ instructions to buy or sell
positions. Those positions selected by the clients can remain in the same portfolio account as the
positions selected by Guild.

See Item 8 for additional information on Guild’s method of analysis and the risks involved in Guild’s
management strategies.

With respect to broker selection, in cases where the client has selected the broker through whom
trades will be placed, Guild may not have discretion to determine the brokerage commissions.
Additionally, where Guild is managing a client’s portfolio under a “dual contract” program (i.e., a
program where the client has a management agreement with Guild and a separately negotiated
agreement with the broker providing that the broker will receive a percentage of the assets under
management as a fee to cover the brokerage commissions), Guild may not have discretion to
determine brokerage commissions. See Item 12 -- Brokerage Practices.

History and Personnel

Guild is a subchapter S corporation incorporated in California in January 1978.

Guild’s office location is 31225 La Baya Drive, Suite 214, Westlake Village, CA 91362.

Montague Guild, Jr. is the Founder of the firm and currently owns 14% of the equity in Guild.
Anthony Danaher is the President of Guild Investment Management, owns 51% of the equity in
Guild, and has been employed by Guild since July 1990. Bronwyn von Abele, Mr. Guild’s daughter,
serves as Vice President and Corporate Secretary and owns 25% of the equity of Guild and has been
an employee of the Company since 2005. Rudolph von Abele serves as Executive Vice President and
Senior Research Analyst and owns 10% of the equity in Guild. Mr. Von Abele has been a full-time
employee of the Company since August 2013.

Guild’s Investment Committee members include Montague Guild, Jr., Anthony Danaher, and

                                                     Guild Investment Management, Inc. ADV Part 2A - Brochure

Rudolph von Abele. The primary portfolio manager for client portfolios is Anthony Danaher. The
Committee meets regularly to decide portfolio allocations, including the countries, industries, and
securities in which Guild should invest. In addition, the committee discusses market strategy, market
timing, and the appropriate exposure several times per week. The portfolio positioning and trading is
based on the research and decisions made by the Investment Committee. Mr. Danaher oversees the
day-to-day portfolio management process and executes the majority of the trades in client portfolios.

Mr. Guild continues to perform global macro research and analysis, manage portfolios, execute
trades, and speak with clients from time to time about their portfolios. Mr. Guild and Mr. Danaher
discuss market strategy and appropriate portfolio asset allocation several times per week. As disclosed
in 2019 and 2020, Mr. Guild underwent successful treatment for squamous cell throat cancer during
2019. Mr. Guild’s subsequent cancer scans have found no remaining cancerous cells.

Montague Guild, Jr. Mr. Guild was born in 1942. He graduated from the University of California at
Santa Barbara with a B.A. in Economics in 1964 and received his M.B.A. in Finance from California
State University, Long Beach in 1968. In the years since founding Guild Investment Management, he
has been a recognized and quoted speaker and commentator on international investing economics and
has been interviewed many times in leading business and financial media, including Barrons, The
Wall Street Journal, Bloomberg, Investment News, CNBC, and Fox Business News. Mr. Guild
conducts global macro research and analysis, serves on the Investment Committee, and speaks with
clients from time to time about their portfolios.

Anthony Danaher. Mr. Danaher was born in 1967. He studied architecture and design at Kansas
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