Lombard Advisers Incorporated

Fees and Compensation
Description

Lombard Advisers bases the fees for its sponsored programs and for Retirement Plan Services
on a percentage of assets under management. The annual fee for the firm’s Advisory
Agreement is provided to the client in writing prior to the start of the relationship.
The annual Advisory Agreement fee is negotiated between the firm, its IAR(s), and client and is
based on a percentage of the net assets (total asset value less debit balance in a margin
account) according to the following guidelines:
         Up to 1.70% on the first $1,000,000
         Up to 1.00% on the next $2,000,000
         Up to .75% on the next $7,000,000.

Lombard Advisers does not charge a minimum fee and may charge a lesser investment
advisory fee based on certain criteria (e.g., historical relationship, type of assets, anticipated
future earning capacity, anticipated future additional assets, dollar amounts of assets to be
managed, related accounts, account composition, negotiations with clients, etc.).

Held Away Asset Management
For Held Away Asset Management accounts, Lombard Advisers provides two methods with
respect to fee determination.
   1. Lombard Advisers bases the fee on a percentage of the market value of the account.

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       The annual fee is negotiated between the firm, its IAR(s), and client and is based on a
       percentage of the market value of the account according to the following guidelines:
         Up to 1.70% on the first $1,000,000
         Up to 1.00% on the next $2,000,000
         Up to .75% on the next $7,000,000
     Lombard Advisers does not charge a minimum fee and may charge a lesser investment
     advisory fee based on certain criteria (e.g., historical relationship, type of assets,
     anticipated future earning capacity, anticipated future additional assets, dollar amounts of
     assets to be managed, related accounts, account composition, negotiations with clients,
     etc.). The annual fee percentage is negotiated at the beginning of the arrangement and
     will be reassessed during the arrangement at regular intervals.

   2. Lombard Advisers also offers a fixed fee subscription-based arrangement for the
      management of held away assets. The subscription-based fixed fee charged is based
      on various factors such as frequency of monitoring, frequency of rebalancing, and
      number of investment choices, with a holistic view of the client relationship. The fixed fee
      is negotiated in advance and agreed upon through the Investment Advisory Agreement.
      The fixed fee is negotiated at the beginning of the arrangement and will be reassessed
      during the arrangement at regular intervals.

Wrap Programs offered through Wells Fargo Clearing Services, LLC (WFCS, LLC)
Clients who choose to participate in a wrap fee program through WFCS, LLC, are typically
charged a single annualized Program Fee based on a percentage of Eligible Program Assets.
The Program Fee covers advisory, execution, custodial, and reporting services. Lombard
Advisers and the IAR receive a portion of this fee.

Each Program’s features and fee schedule may be found within the applicable Client Agreement
as well as within the applicable WFCS, LLC Wrap Fee Brochure. Lombard Advisers will provide
the client with the applicable WFCS, LLC Wrap Fee Brochure and Form CRS. The client may
also receive a Firm Brochure, Form CRS, or other disclosure documents directly from WFCS,
LLC or third-party managers utilized on the WFCS, LLC Platform. These documents should be
carefully reviewed in order to understand WFCS, LLC program features, fee schedules, and
other important information.

Fee Billing

Platform Accounts (held through the clearing firm)
For Lombard Advisers sponsored programs investment management fees are billed quarterly, in
advance, meaning that you are charged at the beginning of the quarterly billing cycle. Payment
in full for each quarter is automatically deducted at the time of billing from the designated
Lombard Securities client platform account, based on the net value of the account on the last

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business day of the most recent month. The client must provide written consent in advance to
direct debiting of their investment account which is detailed in the Investment Advisory
Agreement. Clients are charged $25.00 annually for administrative costs related to the fee-
billing process.

Retirement Plan Services
Fees for advisory services to Retirement Plans are charged as a percentage of the plan’s
assets. The fee schedule is negotiated between the IAR and the Retirement plan and is
memorialized through the advisory agreement. Fees are normally collected via invoice in these
circumstances

Held Away Asset Management
For Held Away Asset Management accounts, Lombard Advisers provides two options with
respect to fee billing.
1. The fee is based on the market value of the client’s held away account at the beginning of
   the arrangement and is reassessed during the arrangement at regular intervals. The annual
   fee is divided by four and the client is invoiced each quarter, in advance. The client pays the
   invoice electronically through ACH via a third-party payment solution in which the client will
   securely input payment information and pay the advisory fee through a secure portal.
   Lombard Advisers will not have access to the Client’s banking information. Payment
   amounts are negotiated in advance and agreed upon through the Investment Advisory
   Agreement.
2. Fixed Fee Subscription Invoice - The subscription-based fixed annual fee amount is based
   on various factors such as frequency of monitoring, frequency of rebalancing, and number of
   investment choices, with a holistic view of the client relationship. The fixed annual fee is paid
   in monthly/quarterly installments by the client electronically through ACH via a third-party
...

Types of Clients
Description

Lombard Advisers generally provides investment advice to individuals, banks or thrift
institutions, investment companies, pension and profit-sharing plans, 401k plans, trusts, estates,
charitable organizations, corporations, or business entities.

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Client relationships vary in scope and length of service.

Account Minimums

There is no account minimum required to participate in a Lombard Advisers’ sponsored
program.
Account minimums for Wrap Programs offered through WFCS, LLC vary. Information regarding
account minimums for the specific Program(s) may be found within the applicable WFCS, LLC
Wrap Fee Brochure. Lombard Advisers will provide the client with the applicable WFCS, LLC
Wrap Fee Brochure and Form CRS. The client may also receive a Firm Brochure, Form CRS,
or other disclosure documents directly from WFCS, LLC or third-party managers utilized on the
WFCS, LLC Platform. These documents should be carefully reviewed in order to understand
WFCS, LLC program features, fee schedules, and other important information.

Form ADV, Part 2A, Item 8
Methods of Analysis, Investment Strategies, and Risk of Loss