Opal Wealth Advisors LLC

ITEM 5 – FEES AND COMPENSATION

A.	 OWA offers services on a fee basis, which includes fixed fees and fees based upon assets under management.
    Additionally, certain of the Firm’s Supervised Persons, in their individual capacities, offers securities brokerage services
    and/or insurance products under a separate commission-based arrangement.

    Wealth Management Fees

    OWA offers wealth management services for an annual fee based on the amount of assets under the Firm’s
    management. This management fee generally varies between 50 and 150 basis points (0.50% and 1.50%) depending
    upon the size and composition of a client’s portfolio and the type of services rendered. The fee can be agreed upon
    based upon a fee schedule with break-points at certain asset levels, or a fixed percentage.

    For asset management services the Firm provides with respect to certain client holdings (e.g., held-away assets,
    accommodation accounts, alternative investments, etc.), OWA may negotiate a fee rate that differs from the range set
    forth above.

    Financial Planning and Consulting Fees

    For financial planning and consulting services that fall outside of the Firm’s wealth management services, OWA charges
    a fixed fee. These fees are negotiable but range from $1,000 to $10,000 depending upon the scope and complexity of
    the services and the professional rendering the financial planning and/or the consulting services. If the client engages
    the Firm for additional investment advisory services, OWA may offset all or a portion of its fees for those services based
    upon the amount paid for the financial planning and/or consulting services.

    Retirement Plan Consulting Fees

    OWA charges fixed project-based fee or asset-based fee to provide clients with retirement plan consulting
    services. Each engagement is individually negotiated and tailored to accommodate the needs of the individual
    plan sponsor, as memorialized in the Agreement. These fees vary and are based on the scope of the services to
    be rendered, including the amount of assets to be managed.

OPAL WEALTH ADVISORS, LLC

    Fee Dispersion

    OWA primarily serves individuals and families, but has also been engaged by entities, including retirement plans. OWA,
    in its discretion, may charge a lesser investment advisory fee, charge a flat fee, or waive its fee entirely based upon
    certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to
    be managed, related accounts, account composition, complexity of the engagement, grandfathered fee schedules, OWA
    employees and family members, courtesy accounts, competition, negotiations with client, etc.). Additionally, OWA’s
    investment advisory fee is negotiable at its discretion, depending upon objective and subjective factors including but not
    limited to: the amount of assets to be managed; portfolio composition; the scope and complexity of the engagement;
    the anticipated number of meetings and servicing needs; related accounts; future earning capacity; anticipated future
    additional assets; the professional(s) rendering the service(s); prior relationships with OWA and/or its representatives,
    and negotiations with the client.

    As result of the above, similarly situated clients could pay different fees than those specifically set forth above. In
    addition, similar advisory services may be available from other investment advisers for similar or lower fees.

    Account Additions and Withdrawals

    Clients can make additions to and withdrawals from their account at any time, subject to OWA’s right to terminate an
    account. Additions can be in cash or securities provided that the Firm reserves the right to liquidate any transferred
    securities or declines to accept particular securities into a client’s account. Clients can withdraw account assets on
    notice to OWA, subject to the usual and customary securities settlement procedures. However, the Firm designs its
    portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment
    objectives. OWA may consult with its clients about the options and implications of transferring securities. Clients are
    advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption
    fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications.

B.	 Clients provide OWA and/or certain Independent Managers with the authority to directly debit their accounts for
    payment of the investment advisory fees. The qualified custodians for client accounts, through which the Firm retains
    the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all
    account transactions, including any amounts paid to OWA. OWA generally deducts its advisory fees on a quarterly
    basis, in advance.

C.	 In addition to the advisory fees paid to OWA, clients also incur certain charges imposed by other third parties, such as
    broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial Institutions”).
    These additional charges include securities brokerage commissions, transaction fees, custodial fees, fees charged
    by the Independent Managers and the UMA platforms used to access them, margin and other borrowing costs,
    charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund
    management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer
    and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions.
...

ITEM 7. TYPES OF CLIENTS

  OWA primarily serves individuals and families, but has also been engaged by entities, including retirement plans. OWA
  may charge a lesser investment advisory fee, charge a flat fee, or waive its fee entirely based upon certain criteria (i.e.,
  anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related
  accounts, account composition, complexity of the engagement, grandfathered fee schedules, OWA employees and
  family members, courtesy accounts, competition, negotiations with client, etc.).

  As result of the above, similarly situated clients could pay different fees. In addition, similar advisory services may be
  available from other investment advisers for similar or lower fees.

  Minimum Account Fee

  As a condition for starting and maintaining an investment management relationship, OWA imposes a minimum
  quarterly fee of $1,250. This minimum fee will cause clients with smaller portfolios to incur an effective fee rate that is
  higher than the Firm’s stated fee schedule. OWA may, in its sole discretion, elect to waive or reduce its minimum fee
  based upon certain criteria, including anticipated future earning capacity, anticipated future additional assets, dollar
  amount of assets to be managed, related accounts, account composition, pre-existing client, account retention, and pro
  bono activities.

OPAL WEALTH ADVISORS, LLC