LVM Capital Management Ltd

Item	5	–	Fees	and	Compensation
LVM receives a fee for wealth management services in an amount established with each client and specified in the client’s
investment advisory agreement. LVM reserves the opportunity to negotiate wealth management fees. The general fee
schedule is:

         Market Value of the Account                  $ or Percent Annual Fee
         < $2 million                                 1.25 %
         $2,000,000 to $5,000,000                     1.00 %
         > $5 million                                 Negotiated

The fee may be higher or lower depending on the size of the account, services rendered, or for a family relationship or
charitable organization. Other fee arrangements may be negotiated with individual clients including fixed fees or hourly
fees, particularly, but not exclusively, in the production of a financial plan. Wealth management fees are invoiced and
payable quarterly in arrears. Fees are based on the market value of each account on the last business day of the quarter.
Clients may choose to have fees debited directly from an advised account or may pay by check. A client may terminate the
investment advisory agreement at any time upon thirty days prior written notice. The fees for the quarter in which
termination occurs will be prorated. When LVM provides investment management only for clients who receive financial
planning from a broker/dealer’s registered representative, the clients total fee is not more than the schedule above. LVM
believes that its fees are fair and reasonable. Other registered investment advisors may offer similar services for fees that
are more or less than LVM’s fees. LVM does not receive commissions from investment products or fees or commissions
generated by securities trades in any client account.

Occasionally LVM grants a fee waiver to a client account. Generally, but not exclusively, this accommodation relates to
small accounts of children of existing clients.

Any client who is invested in shares of mutual funds, exchange traded funds, or other investment companies (“Funds”) is
subject to additional advisory fees and expenses as set forth in the prospectus of such Funds, paid by the Funds, but
ultimately borne by the investor. These fees are in addition to any LVM fees. LVM does not receive any portion of these
fees. LVM’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses incurred
by the client. Clients may incur certain charges imposed by custodians, brokers/dealers, third party investment and other
third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes,
wire transfer and electronic fund fees, trade away fees, and other fees and taxes on brokerage accounts and securities
transactions. Refer to section 12 for more information on LVM’s brokerage practices.

Clients selecting a bank trust company as a custodian typically pay an explicit custody fee to the bank for its services. This
fee is in addition to any LVM fees. All client accounts (except those under a wrap fee) bear the cost of explicit trading
commissions and brokerage fees regardless of custodial arrangement. Occasionally LVM will execute a “trade away”, where
a broker/dealer custodian is not the executing broker/dealer but settles the trade on a delivery versus payment basis.
Generally the broker/dealer custodian charges a nominal flat fee for this service. This fee is in addition to any LVM fees. A
trade away occurs when LVM determines that a client’s total trade proceeds are optimized versus the same trade with the
broker/dealer custodian. Item 12 further describes the factors that LVM considers in selecting or recommending
broker/dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions).

LVM, occasionally and only at the request of a client, reviews and offers advice on interests in partnerships investing in
assets other than real estate or oil and gas interests. LVM receives a wealth management fee on real estate limited
partnerships that are part of a client's managed assets. LVM, as part of its financial planning function for some wealth
management clients, reviews and offers advice on various types of life insurance and annuities. LVM, occasionally, and only
at the request of the client, reviews and offers advice on long term healthcare insurance. LVM does not receive fees or
commissions on the purchase or sale by clients of life insurance, annuities, or long-term care insurance and does not
receive compensation for referring clients to other financial professionals for analysis of these vehicles.

LVM outsources the filing of all securities class action claims to Chicago Clearing Corporation (CCC). CCC is compensated
with a 15% contingency fee paid from the awards it obtains for LVM’s clients. Neither LVM nor its clients pay an explicit or

LVM Capital Management, LTD.            SEC 111039             ADV Part 2A                        Date: September 30, 2025
upfront fee to engage CCC. LVM receives no compensation from CCC. Clients may opt out of CCC’s service by completing
and returning to LVM an opt-out letter.

Item	7	–	Types	of	Clients
LVM provides wealth management services to individuals, high net worth individuals, bank trust departments, corporate
pension and profit-sharing plans, charitable institutions, foundations, endowments, and other U.S. institutions. LVM
generally requires a minimum of $1,000,000 to establish a relationship, but takes into consideration the interrelationships
of accounts and client referrals and occasionally makes exceptions to this guideline.