Palm Springs Advisory LLC

Item	5	-	Fees	and	Compensation

    	Advisor	Managed	Account

    Advisor	Managed	accounts	may	be	custodied	at	Interactive	Brokers		or	Charles	Schwab	&	Co.	(“Schwab”)
    The	specific	manner	in	which			fees	are	charged	by	the	Firm	is	established	in	a	client’s	written	agreement.
    Fees	are	based	on	a	percentage	of	assets	under	management(AUM)	and	calculated	at	an	annual	rate	and
    billed	 in	 arrear	 on	 a	 monthly	 basis,	 AUM	 based	 fees	 are	 based	 on	 the	 assets	 in	 the	 account	 per	 the
    schedule	below	and	in	some	instances.	Client	may	also	be	charged	performance	based	fee	in	arrear	on
    quarterly	basis.	All	fees	charged	by	PSA	is	negotiable.

    AUM	Based	Fees

    The	annual	AUM-based	rates	shown	below	are	PSA’s	maximum	rates.	All	advisory	fees	are	negotiable.
    A	Client’s	actual	rate	may	be	lower	based	on	account	size,	services,	strategy,	relationship	size	and
    other	relevant	factors.	The	final	rate,	valuation	method	and	billing	frequency	will	be	stated	in	the

    Client’s	written	advisory	agreement	and	will	not	exceed	the	applicable	maximum	below.	PSA	use
    traditional	tiered	rate,	which	means	allow	multiple	rates	to	be	applied	across	the	total	account	value.
    For	example,	first	$1	million	billed	at	2%,	the	amount	between	first	$1	million	to	$5	million	billed	at
    1.75%,	and	the	rest	billed	at	1.5%.

    PSA	charges	an	annualized	percentage	of	Net	Liquidation	Value	(NLV),	billed	monthly	in	arrears	and
    deducted	at	the	beginning	of	the	following	month.	Each	Client’s	written	fee	Schedule	must	select	one
    valuation	method:	average	daily	adjusted	NLV	or	month-end	adjusted	NLV.	The	selected	method	applies
    throughout	the	billing	period,	may	not	be	changed	retroactively,	and	may	be	changed	prospectively	only
    by	written	amendment.

                                             AUM	                 Management	Fee
                                         0<$1,000,000	                 2.0%
                                     $1,000,001-$5,000,000	           1.75%
                                        Over	$5,000,000	               1.5%

    Performance	Based	Fee

    If	a	Performance	Fee	arrangement	is	selected,	PSA	may	charge	a	Performance	Fee	only	if,	at	contract
    inception,	the	Client	either:
    (i)     is	 not	 resident	 in	 the	 United	 States	 for	 purposes	 of	 Advisers	 Act	 §205(b)(5),	 based	 on
            documented	facts	and	legal	analysis,	or
    (ii)    is	a	Qualified	Client	under	Rule	205-3.
    Regulation	S	status	alone	does	not	establish	eligibility	under	§205(b)(5).	A	Client	may	pay	both	an	asset-
    based	fee	and	a	Performance	Fee	or,	if	the	applicable	written	Schedule	so	provides,	a	Performance	Fee
    without	an	asset-based	fee.

Performance-based	 fee	 structures	 create	 conflicts	 of	 interest	 because	 the	 Firm	 has	 an	 incentive	 to
recommend	 strategies	 with	 higher	 potential	 returns	 or	 greater	 volatility	 in	 an	 effort	 to	 increase
performance-based	 compensation.	 The	 Firm	 also	 has	 an	 incentive	 to	 favor	 performance-fee	 accounts
over	asset-based	accounts	when	allocating	investment	opportunities.	The	Firm	seeks	to	mitigate	these
conflicts	through	its	fiduciary	duty,	supervisory	oversight,	and	trade	allocation	procedures.

    Advisory	Consultant	Service

    Consulting	services	are	charged	at	up	to	$500	per	hour	or	a	fixed	project	fee	stated	in	a	separate	written
    engagement.	Before	work	begins,	the	engagement	will	state	any	hours	included	in	the	advisory	fee,	the
    scope,	 deliverables,	 estimated	 hours	 or	 fixed	 fee,	 invoice	 schedule,	 termination	 and	 refund	 terms.
    Consulting	fees	are	not	based	on	the	amount,	completion	or	success	of	any	securities	transaction.

    Other	fees

    In	addition	to	the	advisory	fees	paid	to	PSA,	Clients	will	incur	transaction	fees	for	trades	executed	by
    their	chosen	custodian.	These	transaction	fees	are	separate	from	our	firm’s	advisory	fees	and	will	be
    disclosed	by	the	chosen	custodian.	Clients	may	also	pay	holdings	charges	imposed	by	the	chosen

custodian	for	certain	investments,	charges	imposed	directly	by	a	mutual	fund,	index	fund,	or	exchange
traded	fund,	which	shall	be	disclosed	in	the	fund’s	prospectus	(i.e.,	fund	management	fees,	initial	or
deferred	sales	charges,	mutual	fund	sales	loads,	12b-1	fees,	surrender	charges,	variable	annuity	fees,
IRA	and	qualified	retirement	plan	fees,	and	other	fund	expenses),	mark-ups	and	mark-downs,	spreads
paid	to	market	makers,	fees	for	trades	executed	away	from	custodian,	wire	transfer	fees	and	other
fees	and	taxes	on	brokerage	accounts	and	securities	transactions.	Our	firm	does	not	receive	a	portion
of	these	fees.

Mutual	Funds	typically	offer	multiple	share	classes	available	for	investment	based	upon	certain
eligibility	and/or	purchase	requirements.	For	instance,	in	addition	to	the	more	commonly	offered
retail	mutual	fund	share	classes	(typically,	Class	A,	B	and	C	shares),	mutual	funds	may	also	offer
institutional,	or	advisor	share	classes	(the	“lower	cost	share	classes”)	or	other	share	classes	that	are
designed	for	purchase	in	an	account	enrolled	in	investment	advisory	programs.	These	lower	cost
share	classes	usually	have	a	lower	expense	ratio	than	other	shares	classes.	In	addition,	lower	cost
share	classes	often	do	not	charge	a	12b-1	fee.	The	Firm	will	utilize	the	most	appropriate	mutual	fund
share	classes	for	its	portfolio	allocations	available	to	it.	Regardless,	clients	may	still	be	invested	in
funds	with	higher	internal	expenses	when	no	lower	cost	share	classes	for	a	fund	are	available	at	the
custodian	or	the	Client	is	not	eligible	due	to	investment	minimums	or	other	requirements.	Clients
should	understand	that	a	transaction	charge	for	mutual	fund	and	exchange	traded	fund	(ETF)
purchases	and	redemptions	may	occur	in	accordance	with	the	appropriate	custodial	agreement.	The
applicable	transaction	charge	varies	depending	on	the	amount	of	recordkeeping	fees	received	by	the
...

Item	7	-	Types	of	Clients

Palm	 Springs	 Advisory	 provides	 advisory	 services	 to	 individuals,	 corporations,	 business	 entities,
pension	and	profit-sharing	plans,	charitable	organizations,	foundations,	endowments,	estates,	trusts,
and	 other	 institutional	 clients.	 The	 minimum	 account	 size	 is	 $100,000	 but	 can	 be	 less	 at	 the	 Firm’s
discretion.