Ironview Capital Management LLC

Fees and Compensation - Item 5

 Portfolio Management Services Fees
 ICM charges an annual fee of up to 1.50% of the market value of the assets under management for portfolio
 management services. These fees are negotiable depending on factors such as the amount of assets, range of
 investments, and complexity of the client’s financial circumstances, among others. Since this fee is negotiable,
 the exact fee paid by the client will be clearly stated in the advisory agreement signed by ICM and the client.

 Portfolio management fees are primarily payable quarterly, in advance, based on the value of the client’s
 account(s) on the last day of the previous quarter. In some cases, we may bill quarterly in arrears, based on the
 value of the client’s account(s) on the last day of the quarter. The payment arrangement will be listed in the
 advisory agreement. Fees are adjusted for deposits or withdrawals in excess of $100,000. Generally, the custodian
 holding the client’s account will deduct ICM’s fees and any other custodial fees directly from a designated account
 to facilitate billing, provided the client has given written authorization. The qualified custodian will send an
 account statement at least quarterly. This statement will detail all account activity. In limited circumstances, at
 the sole discretion of ICM, we may agree to invoice you directly for our advisory fee or we may negotiate other
 fee payment arrangements.

 At the inception of portfolio management services, the first pay period’s fees will be calculated on a pro-rata
 basis. The portfolio management agreement between the client and ICM will continue in effect until either party
 terminates the agreement in accordance with the terms of the agreement. ICM’s annual fee will be pro-rated
 through the date of termination. Should termination occur at any time other than the end of a billing period, any
 unearned prepaid fee will be refunded to the client.

 Pension Consulting Services Fees
 ICM charges an annual fee of up to 1.00% of the market value of plan assets for pension consulting services. These
 fees are negotiable depending on factors such as the amount of plan assets, range of investments, and complexity
 of the plan’s structure, among others. Since this fee is negotiable, the exact fee paid by the client will be clearly
 stated in the pension consulting agreement signed by ICM and the client.

 Pension consulting fees are generally payable monthly, or quarterly, in arrears, based on the value of plan assets
 on the last day of the previous pay period. Other fee payment arrangements may be negotiated on a case by case
 basis. The exact fee payment arrangement will be listed in the pension consulting agreement.

 The fee is deducted directly from the plan. The qualified custodian of the plan will send an account statement on
 at least a quarterly basis. This statement will detail account activity. Clients are encouraged to review each
 statement for accuracy.

 Additional Fees and Expenses
 Our 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, ICM will not receive any portion of the
 commissions, fees, and costs. Please see Item 12 – Brokerage Practices for further information on brokerage
 arrangements.

 Negotiability of Fees: We allow Associated Persons servicing the account to negotiate the exact investment
 management fees within the range disclosed in our Form ADV Part 2A Brochure. As a result, the Associated Person
 servicing your account may charge more or less for the same service than another Associated Person of our firm.
 Further, our annual investment management fee may be higher than that charged by other investment advisors
 offering similar services/programs.

Ironview Capital Management, LLC
Form ADV Part 2 Brochure

 Billing on Cash Positions: The firm treats cash and cash equivalents as an asset class. Accordingly, unless otherwise
 agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of
 assets under management for purposes of calculating the firm’s advisory fee. At any specific point in time,
 depending upon perceived or anticipated market conditions/events (there being no guarantee that such
 anticipated market conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for
 defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts
 could miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could
 exceed the interest paid by the client’s cash or cash equivalent positions.

 Billing on Margin: Unless otherwise agreed in writing, the gross amount of assets in the client’s account, including
 margin balances, are included as part of assets under management for purposes of calculating the firm’s advisory
 fee. Clients should note that this practice will increase total assets under management used to calculate advisory
 fees which will in turn increase the amount of fees collected by our firm. This practice creates a conflict of interest
 in that our firm has an incentive to use margin in order to increase the amount of billable assets. At all times, the
 firm and its Associated Persons strive to uphold their fiduciary duty of fair dealing with clients. Clients are free to
 restrict the use of margin by our firm. However, clients should note that any restriction on the use of margin may
 negatively impact an account’s performance in a rising market.

 Periods of Portfolio Inactivity: The firm has a fiduciary duty to provide services consistent with the client’s best
 interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to
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Types of Clients - Item 7

 We generally offer investment advisory services to individuals, pension and profit sharing plans, trusts, estates,
 and business entities.

 At this time, ICM requires a minimum of $500,000 to establish and maintain an advisory relationship. In our sole
 discretion, we may waive this requirement. This requirement can be met by combining two or more accounts
 owned by you or related family members.

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

 ICM advisors will use various methods to determine an appropriate investment strategy. We seek to recommend
 investment strategies or products that will give you a diversified portfolio consistent with your investment
 objective. We do this by analyzing the various products, investment strategies, and money management firms to
 which we provide access. That analysis includes a review of the structure, cost, and investment performance
 history of each program.

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

      • Fundamental Analysis – Involves analyzing individual companies and their industry groups, such as a
        company’s financial statements, details regarding the company’s product line, the experience and
        expertise of the company’s management, and the outlook for the company’s industry. The resulting data
        is used to measure the true value of the company’s stock compared to the current market value. The
        primary risk of 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 upon 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.

Ironview Capital Management, LLC
Form ADV Part 2 Brochure

      • Quantitative Analysis – Quantitative Analysis refers to the use of models, or algorithms (i.e., a set of rules
        embedded in a computer program). The process usually consists of searching vast databases for patterns,
        such as correlations among assets or price-movement patterns (trend following or mean reversion). The
        resulting strategies may involve high-frequency trading. The results of the analysis are taken into
        consideration in the decision to buy or sell securities and in the management of portfolio characteristics.
        A risk in using quantitative analysis is that the methods or models used may be based on assumptions
        that prove to be incorrect.

 We may also obtain research from unaffiliated third parties. Prior to engaging the services of any unaffiliated third
 party research provider, ICM will conduct a due diligence review and will maintain records of the review in the
 firm’s compliance files.

 Capital Integration Systems LLC Investments (“CAIS”)
 CAIS sources and selects various private funds for its platform through a due diligence process conducted by
 Mercer Investment Consulting (“Mercer”). Products that are appropriate and desirable for the platform are
 subject to internal committee reviews by CAIS and a fully independent review by Mercer. Product onboarding
 occurs only following the successful completion of these processes.

 Privately Offered Securities valuations can lag a month or more and are provided by the issuer’s third-party
 administrator or CAIS to the custodian. The fee calculation uses this data to calculate the fee.

 In addition to reviewing the risk disclosure contained herein, clients participating in alternative investments
 available to them through CAIS should closely read the relevant prospectus or private placement memorandum
 prior to investing. Such documents are intended to include all material risks of such investments, and are hereby
 incorporated herein by reference.

 ICM does not represent, warrant, or imply that any analysis method employed by the firm can or will successfully
 identify market tops or bottoms. No analysis method has been proven to insulate clients from losses due to
 market fluctuations, corrections, or declines.

 We may use one or more of the following investment strategies when advising you on investments:

      • Long Term Purchases – securities purchased with the expectation that the value of those securities will
        grow over a relatively long period of time, generally greater than one year. Using a long-term purchase
        strategy generally assumes the financial markets will go up in the long-term which may not be the case.
        There is also the risk that the segment of the market that you are invested in or perhaps just your
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