Lyon Capital Management LLC

Item	5	–	Fees	and	Compensation
Fees for Investment Management Services
The annual investment management fee is calculated as a percent of assets in accordance with the fee schedule set forth
below:

                                         Lyon Capital Management, LLC Fee Schedule
                                      1.00% on the first $1,000,000 under management
                                      0.75% on the next $4,000,000 under management
                                          0.50 of 1% on any amount over $5,000,000

                                                  Sample Fee Calculation:
                                                Investments of $1,500,000
                                                    $1,000,000 @ 1.00%
                                                      $500,000 @.75%
                                    Quarterly Fee of $3,437.50 or Annual Fee of $13,750
                                          (Effective annual blended rate of.92%)
The Firm’s investment management fees are negotiable. The Firm requires a portfolio minimum of $500,000 for advisory
engagements. The portfolio minimum may be waived at the sole discretion of the Firm; therefore, the Firm does, in some
instances, manage portfolios of less than $500,000. The Firm may amend the fee schedule with thirty (30) days’ advance
notice to the client.
Billing Procedures
Investment management fees are paid to the Firm quarterly, in advance, based on the value of the assets, including accrued
interest, on the last business day of the previous quarter. The Firm aggregates account values of client investment portfolios
held by members of the same household for advisory fee calculation purposes.
Clients provide written authorization for the Firm to deduct investment management fees directly from their investment
portfolios. This authorization is incorporated in the Firm’s advisory contract for investment management services. Clients
also have the option to remit payment by check directly to the Firm rather than have fees deducted from their account(s).
The Firm uses a portfolio valuation method that is applied to all accounts for fee calculation purposes. We use a single pricing
service (Charles Schwab & Co., Inc.) to value portfolios. We also use the trade date (instead of the settlement date) to value
portfolio assets. We include accrued interest in the value of fixed income securities. We maintain a Fair Valuation Policy for
securities we cannot value using the methods described above.
Other Fees and Expenses
The Firm’s investment management fees are exclusive of brokerage commissions, transaction fees, and mutual fund fees.
Clients will incur additional charges imposed by the account custodian, broker-dealer, and other third parties. These charges
may include but are not limited to trade-away fees (see Item 12 – Brokerage Practices), custodial fees, wire transfer and
electronic fund fees, mailing fees, insufficient funds fees, and other fees and taxes on brokerage accounts and securities
transactions that may be levied by the Securities and Exchange Commission or other regulatory or government entities.
Clients who own mutual funds and exchange-traded funds are assessed fund management fees by the fund company. These
fees are disclosed in each fund company’s prospectus. Clients are urged to review the fund’s prospectus. A full description
of the most recent fees and expenses charged by the account custodian, broker-dealer, and other third parties is available to
clients upon request.
The Firm charges a reduced fee (.5% of assets) for investment supervisory services that do not include active management of
a portfolio’s assets.
Termination Procedures & Refund Policy
As outlined in the Firm’s advisory contract for investment management services, Clients may terminate their contract at any
time by providing thirty (30) days’ advance written notice to the Firm. Clients may also communicate a termination notice to
the Firm by phone or in-person. Upon receipt of a termination request or notice of the death of a client, the Firm will assess
investment management fees pro rata to the date of termination, and any unearned portion of prepaid investment
management fees (based on the number of days remaining in the quarter) will be refunded within fourteen (14) business
days. The Firm will either mail an advisory fee refund check to the client’s address of record or credit the client’s portfolio
directly.

Other Compensation
The Firm does not earn compensation for the sale of securities or other investment products. The Firm’s employees
(supervised persons) are not registered in any investment sales capacity.

Item	7	–	Types	of	Clients
The Firm provides investment management services to individuals, high-net-worth individuals, corporate retirement savings
plans, organizations, trusts, estates, and small businesses.