Hightower Advisors LLC

ITEM 5 – FEES AND COMPENSATION
Types of Fees
Depending upon the type of service to be provided and the Advisor utilized, fees are generally negotiable. Fees may
be calculated and assessed as:
    • A percentage of assets under management, applied as one of the following:
            o Flat percentage rate;
            o Tiered waterfall where the overall percentage rate is blended according to various asset level
                thresholds; or
            o Tiered floating where the overall percentage rate is a flat percentage according to various asset
                level thresholds.
    • Hourly charges
    • Flat fees
    • Other retainer or service fees
    • Some combination of the above

As a result, not all client accounts employing the same or similar investment strategies will have the same or similar
fee structures. Additionally, Hightower, or one of its affiliates, may apply fee waivers, credits or other adjustments
if fees charged to an account are prohibited or otherwise impacted by applicable law, such as ERISA.

Fee Payment and Calculation
Hightower’s primary payment method is to direct the custodian to deduct the investment management fee from a
client’s account(s). Fees may be charged in arrears or advance and are generally expressed as an annual fee
calculated quarterly or monthly according to one or more type of billing methodologies described below, depending
on the type of service and fee.

Billing Methodologies
    •   Quarterly in Arrears: Fees are based on the average daily balance throughout the quarter as the billable
        value when calculating fees. This calculation uses the average daily billable value multiplied by the fee rate
        disclosed in the client advisory agreement multiplied by the prorated number of days in the quarter. The
        frequency of this billing is every three months after quarter-end. Quarters are calendar quarters.
    •   Quarterly Forward: Fees are calculated based on the prior quarter-end billable value to determine the
        quarterly fee in advance. This calculation uses the prior quarter-end billable value multiplied by the fee rate
        disclosed in the client advisory agreement multiplied by the prorated number of days in the quarter. The
        frequency of this billing is every three months after quarter-end. Quarters are calendar quarters.
    •   Monthly Forward: Fees are calculated using the prior month-end billable value to determine the monthly
        fee in advance. This calculation uses the prior month-end billable value multiplied by the fee rate disclosed
        in the client advisory agreement and by the prorated number of days in the month. The frequency is every
        month after the month-end.
    •   Average End of Month in Arrears: Fees are calculated using the average of the preceding three month-end
        values within the quarter. This calculation uses the average billable value multiplied by the fee rate
        disclosed in the client advisory agreement and is multiplied by the prorated number of days in the quarter.
        The frequency of this billing is every three months after quarter-end. Quarters are calendar quarters.
    •   Monthly Arrears: Fees are calculated using the average daily balance throughout the month as the billable
        value when calculating fees. This calculation uses the average daily billable value multiplied by the fee rate
        disclosed in the client advisory agreement that is then multiplied by the prorated number of days in the
        month. The frequency of this billing is every month after the month-end.

Additional Fee Details
    •   Inception and Termination Fees: An investment advisory account opened or terminated mid-billing cycle
        will have its fees prorated by the number of days in the applicable billing cycle and charged or refunded,
        as applicable.
    •   Accrued Interest and Dividends: Accrued interest and dividends are treated as billable values by a majority
        of Advisor Practices.
    •   Householding for Price Break Purposes: At Hightower’s discretion, certain client accounts may be
        ‘householded’ for purposes of fee calculations, depending on the client relationship and overall services
        provided.

Valuation
Hightower charges advisory fees based upon the valuation of client accounts as determined and provided by its
reporting vendors, qualified custodians, Third Party Managers, private fund administrators, and/or from the client
themselves. The total portfolio value on which fees are based may vary from the value on the custodian statement
(the valuation may be higher or lower) due to such factors as the timing and posting of dividends, settlement dates
for trades, etc. In some cases, clients may provide Hightower with pricing for unmanaged securities or real assets
that cannot be (or are not) verified by Hightower (i.e., either cost basis information is no longer or readily available,
including the value of real assets such as a client’s home or art collection, etc.). For client margin accounts, generally
the total long market value (not the net account value) is used when calculating Hightower's fees. In certain cases,
an Advisor Practice may have a margin billing philosophy that differs from this methodology. In these
circumstances, the Advisor Practice may adjust the client’s fee but at no time will the fee adjustment result in a fee
higher than the client’s stated fee schedule and stated margin billing methodology.

Manager Fees and Wrap Fees
In addition to the fees for services provided by the Advisor, a client may also pay a separate Affiliated Manager fee
(“Affiliated Manager Fee”) and/or Third Party Manager fee (“Third Party Manager Fee” and collectively with
Affiliated Manager Fee, the “Manager Fee”).

Within Hightower’s wrap program, fees paid by the client to Hightower for an account within the Advisor Directed
...

ITEM 7 – TYPES OF CLIENTS

Hightower provides investment advisory and sub-advisory services to a wide range of client types, including but
not limited to individuals, ERISA-and non-ERISA governed retirement accounts and other types of pension and
profit sharing plans, trusts, estates, charitable organizations, corporations, registered and private pooled investment
vehicles, insurance companies, banks and other financial institutions, registered investment advisers, and other types
of institutional clients.

Generally, Hightower does not set a minimum annual fee or minimum account size to open or maintain an account.
However, some Advisor Practices do have minimums for fees and/or account size. Hightower’s investment
management services may not be beneficial for certain asset levels or account sizes, as the relatively higher advisory
fees and trading and transaction costs negatively impact performance.

Access to certain investment types or styles (e.g., the utilization by Advisors of certain Third Party or Affiliated
Managers, private placements, etc.) are often limited to certain types of accounts and are subject to account
minimums, which will vary.