Peloton Capital Management

Item	5	–	Fees	and	Compensation

Fees	 are	 based	 on	 the	 value	 of	 clients’	 managed	 portfolio,	 or	 AUM.	 Road	 Map	 financial
planning	services	are	offered	for	a	flat	fee.	In	limited	instances	in	which	advisory	services	are
provided	 to	 clients	 without	 a	 formally	 managed	 discretionary	 account,	 fees	 may	 be
negotiated	and	based	on	an	hourly	rate	(short-term	or	one-time	engagement).

Peloton	Capital	Management’	Fee	Structure	(Annual	Percentage	of	Household	AUM):

   •   Up	to	   $1,000,000	 1.00%
   •   Next		   $1,500,000						0.90%
   •   Next		   $2,500,000	 0.75%
   •   Next		   $5,000,000	 0.65%
   •   Over		   $10,000,000	 0.55%

Not-for-profit	entities	receive	a	discount	of	15	basis	points	in	each	tier.

Fees	are	assessed	quarterly	based	on	the	value	of	AUM	at	the	end	of	the	preceding	quarter.
For	example,	fees	for	calendar	Q1	are	assessed	based	on	closing	values	as	of	December	31	of
the	preceding	year.	Fees	are	invoiced	during	the	first	month	of	the	quarter	(generally	“in
advance”)	of	the	billing	quarter	and	are	payable	within	30	days	of	the	invoice	date.	Fees	are
prorated	for	new	accounts	obtained	during	the	quarter,	and	fees	are	refunded	per	Peloton’s
management	agreement	to	any	accounts	terminated	during	the	quarter	but	after	the	invoice
date.

Peloton's	management	agreement	provides	for	the	cancellation	of	services,	for	any	reason,
by	either	party,	with	30	days'	written	notice.

Peloton’s	fees	are	exclusive	of	brokerage	commissions,	transaction	fees,	and	other	related
costs	 and	 expenses	 which	 are	 incurred	 by	 the	 client.	 Clients	 may	 incur	 certain	 charges
imposed	by	custodians,	brokers,	and	other	third	parties	such	as	custodial	fees,	deferred	sales
charges,	odd-lot	differentials,	transfer	taxes,	wire	transfer	and	electronic	fund	fees,	and	other
fees	and	taxes	(including	foreign	taxes	on	dividends)	on	brokerage	accounts	and	securities
transactions.	 Mutual	 funds	 and	 exchange	 traded	 funds	 also	 charge	 internal	 management
fees,	which	are	disclosed	in	a	fund’s	prospectus.

Such	 charges,	 fees	 and	 commissions	 are	 exclusive	 of	 and	 in	 addition	 to	 Peloton’s	 fee,	 and
Peloton	shall	not	receive	any	portion	of	these	commissions,	fees,	and	costs.
Item	12	further	describes	the	factors	that	Peloton	considers	in	selecting	or	recommending
broker-dealers	 for	 client	 transactions	 and	 determining	 the	 reasonableness	 of	 their
compensation	(e.g.,	commissions).

Item	7	–	Types	of	Clients

Peloton	 provides	 or	 seeks	 to	 provide	 financial	 planning	 and/or	 portfolio	 management
services	 to	 private	 individuals,	 high	 net	 worth	 households,	 corporate	 pension	 and	 profit-
sharing	 plans,	 Taft-Hartley	 plans,	 charitable	 institutions,	 foundations,	 endowments,
municipalities,	private	investment	funds,	and	trust	programs.

Prospective	clients	are	evaluated	using	several	factors,	including	potential	AUM,	prospects
for	future	account	growth,	risk	tolerance,	current	and	future	cash	flow	needs,	investment
expectations,	 and	 understanding	 of	 Peloton's	 approach	 and	 service	 offerings.	 Peloton’s
service	offerings	appeal	to	a	broad	range	of	investors.	Prospects	with	smaller	accounts	may
be	 best	 suited	 for	 the	 Road	 Map	 and/or	 Investment	 Management	 strategies,	 while	 larger
accounts	might	be	best	served	by	our	Private	Client	Group	services.