Innovative Private Wealth Management Inc

Fees and Compensation - Item 5

 Wealth Management Services Fees
 Wealth management fees are billed monthly, in advance, and are based on the value of your portfolio at the end
 of the preceding month. Terms of payment are stated in the advisory agreement signed by the Client and the
 firm. Generally, the portfolio management fee will be deducted from the Client’s account held with a non-
 affiliated, qualified custodian. The qualified custodian will provide the Client with an account statement. This
 statement will detail all account activity, including any fees deducted from the account(s). We may deduct the
 fee from a single, client-designated account to facilitate billing. IPWM will also receive a copy of your account
 statements from the custodian. Please review each statement for accuracy. Please let us know immediately if you
 have questions about or if you did not receive a statement. In our sole discretion, we may also negotiate other
 fee payment arrangements with clients. These payment arrangements will be clearly set forth in the advisory
 agreement signed by the Client and the firm.

 On an annualized basis, IPWM typically charges an annual fee, based upon a percentage of the market value of
 the assets being managed, ranging up to 2.00% of assets under management. We may also negotiate other fee
 schedules, such as an annual fixed fee or an annual percentage of assets under management fee based on a tiered
 fee schedule.

 Our management fees are billed on all securities and investments that we manage as part of your overall portfolio,
 including illiquid positions and investments in private placements. Fees are negotiable depending on factors such
 as the amount of assets under management, range of investments, and complexity of the Client’s financial
 circumstances, among others. The exact fee to be paid by the Client will be clearly stated in the advisory
 agreement signed by the Client and the firm.

 At the inception of wealth management services, the first pay period’s fees will be calculated on a pro-rata basis.
 The advisory agreement between the Client and IPWM will continue in effect until either party terminates the

Innovative Private Wealth Management Inc.
Form ADV Part 2A Brochure

 advisory agreement in accordance with the terms of the advisory agreement. IPWM’s annual fee will be pro-rated
 through the date of termination and any pre-paid, unearned fees will be promptly refunded to the Client.

 Our annual fee is exclusive of, and in addition to, brokerage commissions, transaction fees, and other related
 costs and expenses. You are responsible for brokerage costs incurred. However, IPWM will not receive any portion
 of the commissions, fees, and costs. Please see Item 12 – Brokerage Practices for further information on brokerage
 and transaction costs. We urge clients to review this section in detail to familiarize themselves with the custodial
 fee billing arrangements negotiated with Charles Schwab & Co., Inc. and Digital Trust.

 Financial Consulting Services Fees
 IPWM charges a negotiable hourly fee of $400 for stand-alone financial consulting services. For ongoing consulting
 arrangements, we charge a monthly fee ranging up to $10,000. Prior to engaging IPWM to provide financial
 consulting services, clients will be required to enter into a written financial consulting agreement which will set
 forth the terms and conditions of the engagement and will describe the scope of the services to be provided.

 Fees are typically payable in arrears, but we may negotiate other fee payment arrangements with clients on a
 case-by-case basis, such as monthly fees for ongoing arrangement.

 Either party may terminate the financial consulting agreement by written notice to the other. Refunds are
 typically not applicable since fees are payable in arrears. In the event we negotiate a fee collected in advance, any
 unearned fees will be refunded to the client upon termination.

 Family Office Services Fees
 Fees for Family Office services and wealth management services are bundled into one fee based on a percentage
 of assets under our management in the manner described in the Wealth Management Services section above.
 We generally negotiate our bundled Family Office and wealth management fee schedule at our own discretion.

 Management Services to Pooled Investment Vehicles
 We receive a management fee as the manager and investment adviser to the Funds. These fees are separate from
 and in addition to the advisory fee we charge you for the management of your portfolio. If a client of our firm
 invests in the Funds, IPWM (our firm) will receive two layers of fees on the same assets.

 Certain of the Funds either charge or have the option to charge performance-based fees in addition to the
 management fee. Please refer to the private placement memoranda and other offering documents for more
 information on the management fees associated with investments in the Funds and any performance allocation
 received for the management of the Funds.

 Individual Retirement Account Rollover Disclosures
 As a normal extension of financial advice, we provide education or recommendations related to the rollover of an
 employer-sponsored retirement plan. A plan participant leaving employment has several options. Each choice
 offers advantages and disadvantages, depending on desired investment options and services, fees and expenses,
 withdrawal options, required minimum distributions, tax treatment, and the investor's unique financial needs and
 retirement plans. The complexity of these choices may lead an investor to seek assistance from us.

 An Associated Person who recommends an investor roll over plan assets into an Individual Retirement Account
 (“IRA”) may earn an asset-based fee as a result, but no compensation if assets are retained in the plan. Thus, we
 have an economic incentive to encourage an investor to roll plan assets into an IRA. In most cases, fees and
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Types of Clients - Item 7

 We generally offer investment advisory services to individuals, trusts, estates, charitable organizations,
 corporations and other business entities.

 IPWM generally requires a minimum account size of $100,000 for advisory accounts. However, from time-to-time,
 in its sole discretion, IPWM may accept smaller accounts based on various criteria, such as anticipated future
 assets, related accounts, and other factors.

 With respect to investors in the Funds who are “U.S. Persons,” investments in the Funds, and Series of the Funds,
 are offered and sold only to “accredited investors” as that term is defined in Rule 501(a) of Reg D under the

Innovative Private Wealth Management Inc.
Form ADV Part 2A Brochure

 Securities Act. Individuals (i.e., natural persons) may qualify as accredited investors if they meet certain
 professional criteria, or either of the following financial criteria:
     • Net worth over $1 million, excluding primary residence (individually or with spouse or partner);
     • Income over $200,000 (individually) or $300,000 (with spouse or partner) in each of the prior two years,
          and reasonably expects the same for the current year.

                        Methods of Analysis, Investment Strategies and Risk of Loss - Item 8
                      4B=

 Our investment strategies and advice may vary depending on your specific financial situation. As such, we
 determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial
 horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and
 guidelines may affect the composition of your portfolio.

 We may use one or more of the following methods of analysis when providing investment advice to you:

     •   Fundamental Analysis – Fundamental analysis is a method of evaluating a company or security by
         attempting to measure its intrinsic value. In other words, trying to determine a company’s or a security’s
         true value by looking at all aspects of the business, including both tangible factors (e.g., machinery
         buildings, land, etc.) and intangible factors (e.g., patents, trademarks, “brand” names, etc.). Fundamental
         analysis also involves examining related economic factors (e.g., overall economy and industry conditions,
         etc.), financial factors (e.g., company debt, interest rates, management salaries, and bonuses, etc.),
         qualitative factors (e.g., management expertise, industry cycles, labor relations, etc.), and quantitative
         factors (e.g., debt-to-equity and price-to-equity ratios). The end goal of performing fundamental analysis
         is to produce a value that an investor can compare with the security's current price in hopes of
         determining what sort of position to take with that security (underpriced = buy, overpriced = sell or
         short). This method of security analysis is considered the opposite of technical analysis. Fundamental
         analysis is about using real data to evaluate a security's value. Although most analysts use fundamental
         analysis to value stocks, this method of valuation can be used for just about any type of security. The risk
         associated with fundamental analysis is that information obtained may be incorrect and the analysis may
         not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities
         prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable
         performance.

      • Technical Analysis – Technical analysis is a technique that relies on the assumption that current market
        data (such as charts of price, volume, and open interest) can help predict future market trends, at least
        in the short term. It assumes that market psychology influences trading and can predict when stocks will
        rise or fall. Technical trading models are mathematically driven based on historical data and trends of
        domestic and foreign market trading activity, including various industry and sector trading statistics
        within such markets. Technical trading models, through mathematical algorithms, attempt to identify
        when markets are likely to increase or decrease and identify appropriate entry and exit points. The
        primary risk of technical trading models is that historical trends and past performance cannot predict
        future trends, and there is no assurance that the mathematical algorithms employed are designed
        properly, updated with new data, and can accurately predict future market, industry, and sector
        performance.

     •   Cyclical Analysis – Cyclical analysis is similar to technical analysis in that it involves the analysis of market
         conditions at a macro (entire market/economy) or micro (company specific) level, rather than the overall

Innovative Private Wealth Management Inc.
Form ADV Part 2A Brochure

         fundamental analysis of the health of the particular company. The primary risks with cyclical analysis are
         similar to those of technical analysis.

 Charting Analysis – Charting analysis involves the gathering and processing of price and volume pattern
 information for a particular security, sector, broad index, or commodity. This price and volume pattern
 information is analyzed. The resulting pattern and correlation data is used to detect departures from expected
 performance and diversification and predict future price movements and trends. The primary risk of charting
 analysis is that it may not accurately detect anomalies or predict future price movements. Current prices of
 securities may reflect all information known about the security and day-to-day changes in market prices of
 securities may follow random patterns and may not be predictable with any reliable degree of accuracy.
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