Lyons Capital Group LLC

Item 5 - Fees and Compensation

LCG charges fees based on a percentage of assets under management as well as fixed fees, depending on the particular types
of services to be provided. The specific fees charged by LCG for services provided will be set forth in each client’s
agreement.

Financial Planning and Investment Management Services

Fees for Investment Management Services
LCG charges an investment management services fee that is agreed upon with each client and set forth in an agreement
executed by LCG and the client. The investment management services fee for the initial month shall be paid, on a pro rata
basis, in arrears, based on the value of the net billable assets under management at the end of such initial month. For

subsequent months, the investment management services fee shall be paid, in advance, based on the asset value of the
client’s accounts as of the last business day of the preceding month. The asset value of a client’s account is determined as
provided by third-party sources, such as pricing services, custodians, fund administrators, and client-provided sources. For
purposes of fee calculation, the asset value of client accounts include cash and cash equivalents, as well as margined
securities. LCG does not reduce investment management services fees for margin borrowing, regardless of whether the
assets are in cash or other securities. LCG has a financial incentive to recommend that clients borrow money for the purchase
of additional securities for the client’s account managed by LCG or otherwise not liquidate some or all the assets LCG
manages. LCG addresses this conflict of interest by this disclosure and working to ensure that any recommendation to a
client regarding the use of margin is suitable for the client.

Following is LCG’s asset based fee schedule for investment management services:

                                                 FEE SCHEDULE
                                 Market Value of Assets                   Rate
                              Up to $500,000                             1.50%
                              $500,001 to $1,000,000                     1.25%
                              $1,000,001 to $10,000,000                  1.00%
                              $10,000,001 and above                    negotiable
                              The percentage for the highest range of Managed Asset
                              value achieved applies to all Managed Assets, not just
                              Managed Assets within that range.

LCG’s policy is to include all related client accounts, specifically the accounts of direct family members sharing the same
residence address, for purposes of determining a client’s market value of assets.

Fees for Financial Planning and Consulting Services
Clients that are receiving financial planning services only are charged a fixed fee ranging up to $10,000, depending upon
the complexity of a client’s plan and services provided. The fixed fee for financial planning services can be charged in
monthly installments, or otherwise in full upon delivery of the completed financial plan and, therefore, after completion of
the financial planning services by LCG. Actual fees charged are clearly outlined in the financial planning agreement and
clients receive invoices reflecting the amount of the fee due and payable.

Fees for Investment Management Services to Retirement Plans
Retirement plan advisory clients will be charged an annual asset based fee that ranges from 0.25% to 1.00%, depending on
the complexity of the services provided and the size and scope of the plan. Generally investment management services fees
are paid monthly, in advance. However, the timing and manner of payment of investment management services fees are
determined in coordination with the plan client and the service providers to the plan client, such as plan administrators and
recordkeepers.

Notwithstanding the foregoing, LCG and the client may choose to negotiate an advisory fee that varies from the schedule
and ranges set forth above. Factors upon which a different advisory fee may be based include, but are not limited to, the
size and nature of the relationship, the services rendered, the nature and complexity of the products and investments
involved, time commitments, and travel requirements. The investment management services fee charged by the Firm will
apply to all of the client’s assets under management, unless specifically excluded in the client agreement. Although LCG
believes that its fees are competitive, clients should understand that lower fees for comparable services may be available
from other sources and firms.

The investment advisory agreement between LCG and the client may be terminated at will by either LCG or the client upon
written notice. LCG does not impose termination fees when the client terminates the investment advisory relationship,
except when agreed upon in advance.

Payment of Fees
LCG generally deducts its investment management services fee from a client’s investment account(s) held at his/her
custodian. Upon engaging LCG to manage such account(s), a client grants LCG this limited authority through a written
instruction to the custodian of his/her account(s). The client is responsible for verifying the accuracy of the calculation of
the investment management services fee; the custodian will not determine whether the fee is accurate or properly calculated.
A client may utilize the same procedure for financial planning or consulting fees if the client has investment accounts held
at a custodian.

Although clients generally are required to have their investment management services fees deducted from their accounts, in
some cases, LCG will directly bill a client for investment management services fees if it determines that such billing
arrangement is appropriate given the circumstances.
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Item 7 - Types of Clients

LCG offers investment advisory services to individuals, including high net worth individuals, families, family offices, trusts,
businesses, charitable foundations, and retirement/profit-sharing plans. LCG does not impose a minimum portfolio size or
a minimum initial investment to open an account. However, LCG does reserve the right to accept or decline a potential
client for any reason in its sole discretion.