Imperium Wealth Management LLC

Item 5. Fees and Compensation

   Investment Management Fees
   The firm provides investment management services for an annual fee based upon a
   percentage of the market value of the assets being managed. The annual fee is exclusive of,
   and in addition to brokerage commissions, transaction fees, and other related costs and
   expenses which are incurred by the client. IWM does not, however, receive any portion of these
   commissions, fees, and costs. The firm’s annual fee is prorated and charged quarterly, in
   advance based upon the market value of the assets being managed on the last day of the
   previous quarter. The firm charges an initial minimum fee of $2,250 for new clients of the Firm
   at the start of the first quarter in which the Client engages us. Any portion of this initial fee that
   exceeds the standard Assets Under Management (AUM) fee will be credited towards the fees
   for the following quarter. Clients whose initial AUM fee is higher than the minimum fee will pay
   the standard AUM fee in advance. The annual fee is also negotiable under special
   circumstances. The annual fee is based on the market value of the assets under management,
   as follows:

Imperium Wealth Management, LLC Disclosure Brochure

                                 PORTFOLIO VALUE                       BASE FEE

                                     up to $750,000                     1.15%

                                     Next $750,000                      0.95%

                                    Next $1,000,000                     0.75%

                                    Next $2,500,000                     0.65%

                                   above $5,000,000                     0.45%

   The firm, in its sole discretion, may negotiate to charge a lesser management fee based upon
   certain criteria (e.g., related accounts, anticipated future additional assets, dollar amount of
   assets to be managed, account composition, pre-existing client, account retention, pro bono
   activities, etc.).

   Financial Planning Services Fees
   IWM generally charges a fixed and/or hourly fee for providing financial planning and consulting
   services under a stand-alone engagement. These fees are negotiable, but generally range
   from $2,000 to $10,000 on a fixed fee basis and/or $800 on an hourly basis, depending upon
   the scope and complexity of the services and the professional rendering the financial planning
   and/or the consulting services. If the client engages the Firm for additional investment advisory
   services, IWM may offset all or a portion of its fees for those services based upon the amount
   paid for the financial planning and/or consulting services.
   The terms and conditions of the financial planning and/or consulting engagement are set forth
   in the Advisory Agreement and IWM generally requires one-half of the fee (estimated hourly or
   fixed) payable upon execution of the Advisory Agreement. The outstanding balance is
   generally due upon delivery of the financial plan or completion of the agreed upon services.
   The Firm does not, however, take receipt of $1200 or more in prepaid fees in excess of six
   months in advance of services rendered.

   Retirement Plan Consulting Fees
   IWM charges as fixed project-based fee to provide clients with retirement plan consulting
   services. Each engagement is individually negotiated and tailored to accommodate the needs
   of the individual plan sponsor, as memorialized in the Agreement. These fees vary, based on
   the scope of the services to be rendered.

   Fees Charged by Financial Institutions

Imperium Wealth Management, LLC Disclosure Brochure

   As further discussed in response to Item 12 (below), IWM generally recommends that clients
   utilize the brokerage and clearing services of certain custodian broker-dealers (“Financial
   Institutions”) for investment management accounts. These Financial Institutions offer to
   independent investment advisors services which include custody of securities, trade execution,
   clearance and settlement of transactions. IWM receives some benefits from Financial
   Institutions through its participation in their respective programs.
   IWM may only implement its investment management recommendations after the client has
   arranged for and furnished IWM with all information and authorization regarding accounts with
   appropriate financial institutions. Financial institutions include any broker-dealer recommended
   by IWM, broker-dealer directed by the client, trust companies, banks etc. (collectively referred
   to herein as the “Financial Institutions”).
   Clients may incur certain charges imposed by the Financial Institutions and other third parties
   such as custodial fees, charges imposed directly by a mutual fund or ETF in the account, which
   are disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses),
   deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund
   fees, and other fees and taxes on brokerage accounts and securities transactions. Additionally,
   for assets outside of the Program, clients may incur brokerage commissions and transaction
   fees. Such charges, fees and commissions are exclusive of and in addition to IWM’s fee.
   The firm’s Agreement and the separate agreement with any Financial Institutions authorize
   IWM to debit the client’s account for the amount of IWM’s fee and to directly remit that
   management fee. The Financial Institutions recommended by IWM have agreed to send a
   statement to the client, at least quarterly, indicating all amounts disbursed from the account
   including the amount of management fees paid directly to IWM.

   Fees for Management During Partial Quarters of Service
   For the initial period of investment management services, the fees are calculated on a pro rata basis.
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Item 7. Types of Clients

   IWM provides its services to individuals, pension and profit sharing plans, trusts, estates,
   corporations and business entities.

   Minimum Fee
   The firm does not require either a minimum fee or account balance except for clients in the
   Program who are subject to a minimum annual fee of $9,000.