Leeds Capital Group LLC

Fees and Compensation - Item 5

 Wealth Management Services Fees
 Detailed information about the Stirling Financial Group Wrap Fee Program and program fees is provided in the
 Form ADV Part 2A, Appendix 1 (Wrap Brochure) that is attached to this Form ADV Part 2A Disclosure Brochure.
 Please refer to that portion of this Brochure for further information.

 Financial Consulting Services
 We charge a fixed fee for financial consulting services that may range up to $10,000 depending on the scope of
 services requested by the client. The fee is generally due upon completion of the consulting project, but we my
 negotiate other fee-paying arrangements. You may terminate the agreement by providing written notice to our
 firm. You will incur a pro rata charge for services rendered prior to the termination of the agreement. Once the
 services have been rendered pursuant to the terms of our agreement, any additional consulting services will
 require the client to engage of our firm by entering into a new, separate agreement.

 Pension Consulting Services Fees
 The compensation arrangement for pension consulting services is based on a percentage of the plan assets
 ranging up to an annual fee of 1.00% of plan assets. Services will be negotiated on a case-by-case basis. The exact
 services to be provided, the fee to be paid by the Client, fee payment arrangements, how to terminate the
 contract, and other terms will be clearly stated in the agreement signed by the Client and Stirling Financial Group.

 LPL Sponsored Program – OMP
 We bill an annual flat fee of 1.00% of assets under management for our services rendered under the OMP
 program. This fee is typically billed quarterly (not based on the calendar quarter), in advance and is based on the
 value of your portfolio on the last business day of the preceding quarter. At our sole discretion, fees are
 negotiable depending on factors such as the amount of assets under management, range of investments, and
 complexity of your financial circumstances, among others. Stirling Financial Group may also negotiate other fee-
 paying arrangements, such as monthly or quarterly in arrears, for example. Fees will be assessed pro rata in the
 event the Agreement is executed at any time other than the first day of a billing period.

 Either party may terminate the agreement upon fifteen (15) days' written notice. You will incur a pro rata charge
 for services rendered prior to the termination of the agreement, which means you will incur advisory fees only in
 proportion to the number of days in the billing period for which you are a client. If you have pre-paid advisory
 fees that we have not yet earned, you will receive a prorated refund of those fees.

 Additional Fees and Expenses
 Fees are negotiable based on the amount of assets under management, complexity of Client goals and objectives,
 and level of services rendered. As described above, the fees are charged as described and are not based on a
 share of capital gains of the funds of any advisory Client.

 All fees paid to Stirling Financial Group for investment advisory services are separate and distinct from the fees
 and expenses charged to shareholders by mutual funds or exchange traded funds. These fees and expenses are
 described in each fund's prospectus. These fees generally include a management fee, other fund expenses, and a
 possible distribution fee. In the rare occasion where a fund also imposes sales charges, a Client will pay an initial
 or deferred sales charge.

 A Client could invest in a mutual fund directly, without the services of Stirling Financial Group. In which case, the
 Client would not receive the services provided by Stirling Financial Group, which are designed, among other
 things, to assist the Client in determining which mutual fund or funds are most appropriate to their financial
 condition and objectives. Accordingly, Clients should review the fees charged by the funds and the fees charged

Stirling Financial Group
Form ADV Part 2A & 2A Appendix 1

 by Stirling Financial Group to fully understand the total amount of fees charged and to evaluate the cost of
 advisory services being provided.

 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.

 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
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Types of Clients - Item 7

 Stirling Financial Group does not require a minimum account size to establish an advisory relationship. However,
 third-party investment advisers and third-party sponsored programs may have minimum account sizes. For
 example, participation in the OMP program requires a minimum account size of $10,000.

 We generally offer our wrap fee program to individuals, pension and profit-sharing plans, trusts, estates,
 charitable organizations, corporations, and other business entities.

Stirling Financial Group
Form ADV Part 2A & 2A Appendix 1

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

 Methods of Analysis, Investment Strategies and Risk of Loss
 The investment advice provided along with the methods of analysis and the strategies recommended by Stirling
 Financial Group will vary depending on your specific financial situation and goals. There are many risks to consider.
 This brochure does not disclose all of the possible risks and other significant aspects of investing in financial
 markets. In light of the risks, you should fully understand the nature of the contractual relationship(s) into which
 you are entering and the extent of your risk exposure. Certain investment strategies may not be suitable for
 everyone. You should carefully consider whether the strategies employed would be appropriate for you in light
 of your experience, objectives, financial resources, and other relevant circumstances.

 Investing in securities involves a risk of loss that you should be prepared to bear. We cannot and do not
 represent, warrant, or imply that the services or methods of analysis employed by us can or will predict future
 results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or
 declines.

 Stirling Financial Group generally uses the following methods of analysis:
       • Fundamental Analysis is a technique that attempts to determine a security’s value by focusing on
           underlying factors that affect a company's actual business and its future prospects. The term refers to
           the analysis of the economic well-being of a financial entity as opposed to only its price movements.
       • 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.
       • Cyclical Analysis is a technique used to analyze the investments sensitive to business cycles and whose
           performance is strongly tied to the overall economy. For example, cyclical companies tend to make
           products or provide services that are in lower demand during downturns in the economy and higher
           demand during upswings. Examples include the automobile, steel, and housing industries. The stock
           price of a cyclical company will often rise just before an economic upturn begins, and fall just before
           a downturn begins. Investors in cyclical stocks try to make the largest gains by buying the stock at the
           bottom of a business cycle, just before a turnaround begins. Risks associated with business cycles or
           other economic cycles can adversely affect the returns of an investment, an asset class, or an individual
           company's profits. Cyclical risk does not typically have a tangible measure. Instead, it is reflected in the
           prices or valuations of assets that are deemed to have higher or lower cyclical risks than the market.
           Some companies are more volatile than others, struggling during an economic slowdown and excelling
           when a recovery is underway.

 Investment Strategies
 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, 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 particular investment will go down over time even if

Stirling Financial Group
Form ADV Part 2A & 2A Appendix 1

 the overall financial markets advance. Purchasing investments long-term may create an opportunity cost -
 "locking up" assets that may be better utilized in the short-term in other investments.

 Short Term Purchases – securities purchased with the expectation that they will be sold within a relatively short
 period of time, generally less than one year, to take advantage of the securities' short-term price fluctuations.
 Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform
 in the short-term which may be very difficult and will incur a disproportionately higher amount of transaction
 costs compared to long-term trading. Many factors can affect financial market performance in the short-term
 (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a smaller impact
 over longer periods.

 Trading – securities are sold within 30 days. The principal type of risk associated with trading is market risk. There
 can be no assurance that a specific investment will achieve its investment objectives and past performance should
 not be seen as a guide to future returns. The value of investments and the income derived may fall as well as rise
 and investors may not recoup the original amount invested. Investments may also be affected by any changes in
 exchange control regulation, tax laws, withholding taxes, international, political, and economic developments,
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