No Fate BWWM LLC

Item5, Fees and Compensation. Advisor’ fees are not set or supervised by Schwab. Advisor does not pay
     SPT or Schwab fees for the Platform as long as it maintains $100 million in client assets in accounts at
     Schwab that are not enrolled in the Program. This arrangement presents a conflict of interest, as it
     provides an incentive for Advisor to recommend that clients maintain their accounts at Schwab. Advisor
     would therefore generally recommend to clients that they maintain accounts at Schwab if that is
     consistent with the considerations discussed in Item 12 below, which mitigates this conflict of interest.

     Clients enrolled in the Program are limited in the universe of investment options available to them. For
     example, the investment options available are limited to ETFs, mutual funds, and cash/cash equivalents,
     whereas Advisor can recommend various other types of securities in its other services. Clients will have
     access to their accounts and a financial interface online but can also confer with Advisor with respect to
     their account. Please also refer to Item 8 below with respect to the investment risks associated with the
     Program, including mutual fund and ETF risk.

            Rebalancing
            The System will rebalance a client’s account periodically by generating instructions to Schwab
            to buy and sell shares of funds and depositing or withdrawing funds through the “Sweep
            Program”, considering the asset allocation for the client’s investment strategy. Rebalancing trade
            instructions can be generated by the System when (i) the percentage allocation of an asset class
            varies by a set parameter established by Advisor, (ii) Advisor decides to change the ETFs or
            their percentage allocations for an investment strategy or (iii) Advisor decides to change a
            client’s investment strategy, which could occur, for example, when a client makes changes to
            their investment profile or imposes or modifies restrictions on the management of their account.
            Accounts below $5,000 may deviate farther than the set parameters as well as the target
            allocation of the selected investment profile. Rebalancing below $5,000 may impact the ability to
            maintain positions in selected asset classes due to the inability to buy or sell at least one share of
            an ETF or mutual fund. For example, withdrawal requests may require entire asset classes to be
            liquidated to generate and disburse the
            requested cash.

            Sweep Program
            Each investment strategy involves a cash allocation (“Cash Allocation”) that will be held in a
            sweep program at Charles Schwab Bank (the “Sweep Program”). The Cash Allocation will be a
            minimum of 4% of an account’s value to be held in cash, and may be higher, depending on the
            investment strategy chosen for a client. The Cash Allocation will be accomplished through
            enrollment in the Sweep Program, which is sponsored by Schwab. By enrolling in the Program,

Disclosure Brochure

             clients consent to having the free credit balances in their brokerage accounts at Schwab swept
             into deposit accounts (Deposit Accounts) at Charles Schwab Bank (Schwab Bank) through the
             Sweep Program.

             Schwab Bank is an FDIC-insured depository institution that is a Schwab affiliate. The Sweep
             Program is a required feature of the Program. If the Deposit Account balances exceed the Cash
             Allocation for a client’s investment strategy, the excess over the rebalancing parameter will be
             used to purchase securities as part of rebalancing. If clients request cash withdrawals from their
             accounts, this likely will require the sale of fund positions in their accounts to bring their Cash
             Allocation in line with the target allocation for their chosen investment strategy. If those clients
             have taxable accounts, those sales may generate capital gains (or losses) for tax purposes. In
             accordance with an agreement with Schwab, Schwab Bank has agreed to pay an interest rate to
             depositors participating in the Sweep Program that will be determined by reference to an index.

         •   Compensation to Schwab under the Program
             Clients do not pay fees to SPT or brokerage commissions or other fees to Schwab as part of the
             Program. However, Schwab receives other revenues including but not specifically limited to the
             following which is subject to change: (i) the profit earned by Charles Schwab Bank, on the
             allocation to the Schwab Intelligent Portfolios Sweep Program described in the Schwab
             Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/or
             administrative service fees (or unitary fees) received by Charles Schwab Investment
             Management, Inc., a Schwab affiliate, from Schwab ETFs™ Schwab Funds® and Laudus
             Funds® that Advisor selects to buy and hold in the client’s brokerage account; (iii) fees received
             by Schwab from third-party ETFs that participate in the Schwab ETF OneSource™ program and
             mutual funds in the Schwab Mutual Fund Marketplace® (including certain Schwab Funds and
             Laudus Funds) in the client’s brokerage account for services Schwab provides; and (iv)
             remuneration Schwab may receive from the market centers where it routes ETF trade orders for
             execution.

     Soft Dollars - Soft dollars are revenue programs offered by broker/dealers whereby an advisor enters
     into an agreement to place security trades with the broker in exchange for research and other services.
...

Item 7 – Types of Clients
The advisory services offered by NFWM are available for individuals, individual retirement accounts (“IRAs”),
banks and thrift institutions, pension and profit-sharing plans, including plans subject to Employee Retirement
Income Security Act of 1974 (“ERISA”), trusts, estates, charitable organizations, state and municipal
government entities, corporations and other business entities.