Nine30 Advisors LLC

Item 5:      Fees and Compensation
 Fees for Retail Clients
We manage accounts under $100,000 free of charge; no advisory fee is deducted from these
accounts.

For accounts of $100,000 or more, we charge an annual advisory fee of 0.75% of assets under
management, deducted monthly in arrears from the client’s custodial account. The fee is
calculated monthly based on the end of day account values for the period. Accounts terminated
during the month will be charged the accrued amount. Fees will be charged directly from your
account. If your account crosses the $100,000 threshold during a month, the fee will apply
beginning with the first full month in which the balance remains at or above $100,000. An account
which has crossed above $100,000 will be considered a fee paying account and will continue to
be charged this fee unless the account value crosses below $75,000 as of the last day of the
month.

 Negotiability of Fees
Advisory fees for institutional clients and certain large accounts may be negotiable. Factors
considered include the size of the account, anticipated future assets, the type of client, related
accounts, and the scope of services requested.

 Other Fees and Expenses

In addition to our advisory fee, clients are responsible for other fees and expenses charged by
third parties, such as brokerage commissions, custodial fees, wire transfer fees, account
maintenance fees, and expenses of mutual funds and exchange-traded funds (ETFs). These fees
are separate from our advisory fee and will reduce investment returns.

  Conflicts of Interest
Because we do not charge a fee on accounts below $100,000, we have an incentive to encourage
clients to increase assets above that level. In addition, clients with larger accounts may be offered
access to additional investment strategies, which creates an incentive for us to promote higher
balances.

The advisory fee is due beginning on the date of the Client’s initial engagement and on the
monthly anniversary of that date thereafter, with the advisory fee amount based on the amount of
the Client’s initial deposit, for the first month of service, and value of the Client Account on the
monthly anniversary date thereafter. A Client who engages the Firm on the 29th, 30th or 31st of
a month will be billed on the last day of each calendar month with fewer days. Upon termination,
the Firm’s services will continue through the end of the current billing period and no refund of the
advisory fee will be given. Clients authorize NINE30 to charge the fees to the funding account via
a third-party service provider, Plaid.

Clients will incur certain third-party costs in addition to the fees they pay to NINE30. NINE30 does
not charge these to Clients and does not benefit directly or indirectly from any such charges.
These types of charges include, but are not limited to, wire transfer fees, paper statement fees,
and bounced check fees. The issuer of some of the securities purchased for Clients, such as
ETFs and ADRs, may charge product fees and expenses that affect Clients. An ETF typically
includes embedded expenses that may reduce the fund’s net asset value, and therefore directly
affect the fund’s performance and indirectly affect a Client’s portfolio performance or an index
benchmark comparison. For additional information about the Firm’s brokerage practices, see Item
12 of this Brochure.

Clients may deposit and withdraw from their account at any time, subject to NINE30’s right to
terminate a Client’s account. Deposits to an account must be done via bank transfer from the
Client’s funding account to the Client Account. Clients may withdraw account assets at any time,
subject to the usual and customary securities settlement procedures. However, NINE30 designs
its portfolios as long-term investments, and the withdrawal of assets may impair the achievement
of a Client’s Investment Needs. Clients are advised that when cash is withdrawn, the Client
Account may be subject to transaction fees, and/or tax ramifications.

Neither the Firm nor any of its supervised persons accept compensation for the sale of securities
or other investment products.

Fees on Cash Balances and Bank Sweep Program
Cash held in a Client's Cash Reserve and swept into the Alpaca FDIC Bank Sweep Program is
included in the Client's total assets under management for the purpose of calculating NINE30's
0.75% annual advisory fee. Because NINE30 charges an asset-based fee on these cash
balances, a conflict of interest exists because a Client may pay more in advisory fees on their
cash balance than the yield or interest they earn through the Bank Sweep Program.

NINE30 does not receive any revenue sharing, interest-rate spread, payments, credits, or other
compensation from Alpaca, participating banks, or any other third party in connection with a
Client’s enrollment or cash balances in the Bank Sweep Program.

Item 7:     Types of Clients
The Firm generally provides investment advice to individuals, including high-net worth individuals.
The Firm does not maintain requirements for opening or maintaining an account, such as a
minimum account size.

We provide investment advisory services primarily to individual retail investors. We also make our
services available to institutional clients, including entities such as businesses, and foundations.

NINE30 requires a minimum initial deposit of $10. However, only accounts of $100,000 or more
are subject to advisory fees and may have access to certain additional investment strategies.
Fees for institutional accounts are negotiable, and certain minimum account sizes may apply in
those cases.