Position Wealth LLC

Item 5 Fees and Compensation
Position Wealth offers services for fees based upon assets under management. Additionally, the
Firm anticipates that certain of the Firm's Supervised Persons, in their individual capacities, will
offer insurance products under a separate commission-based arrangement separate and apart
from the advisory services offered by Position Wealth.

Investment Management Fees

Position Wealth offers investment management services for an annual fee based on the amount of
assets under the Firm's management. This management fee varies between 25 and 150 basis points
(0.25% – 1.50%), depending upon the size and composition of a client's portfolio, the type of services
rendered, and the IAR providing the services.

The annual fee is prorated and charged monthly, in advance, based upon the market value of the
assets being managed by Position Wealth on the last day of the previous month. Valuation is provided
by an independent third party that collects data from the custodian of the assets.

If assets are deposited into or withdrawn from an account after the inception of a billing period, the fee
payable with respect to such assets is not adjusted to reflect the interim change in portfolio value. For
the initial period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory
agreement is terminated, the fee for the final billing period is prorated through the effective date of the
termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as
appropriate.

Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage
Position Wealth for additional services for compensation, including rolling over retirement accounts or
moving other assets to the Firm's management. Clients retain absolute discretion over all decisions
regarding engaging the Firm and are under no obligation to act upon any of the recommendations.

Fee Discretion

Position Wealth may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria,
such as assets under management, range of investments, complexity of financial circumstances,
anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be
managed, related accounts, account composition, pre-existing/legacy client relationship, account
retention and pro bono activities.

Additional Fees and Expenses

In addition to the advisory fees paid to Position Wealth, clients also incur certain charges imposed by
other third parties, such as broker-dealers, custodians, trust companies, banks and other financial
institutions (collectively "qualified custodians"). These additional charges include securities brokerage
commissions, transaction fees, custodial fees, margin 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.
The Firm's brokerage practices are described at length in Item 12, below.

Advisory fees charged by Independent Managers are separate and apart from the Firm's fees.
Advisory fees paid to the Independent Managers are established and payable in accordance with the
disclosure brochure and/or client agreement provided by each Independent Manager to whom the
client is recommended. These fees may or may not be negotiable. Position Wealth anticipates that in

some cases, the Firm will share in the fee charged by the Independent Manager. Depending on the
Independent Manager, clients may or may not be able to negotiate the portion of the fee payable to
Position Wealth. The client will generally be required to sign an agreement directly with the
Independent Manager.

Since Position Wealth’s compensation may differ depending upon the use of a particular Independent
Manager (where the Independent Manager shares its fee with the Firm), the Firm has an incentive to
recommend one Independent Manager over another. At all times Position Wealth and its Supervised
Persons will uphold their fiduciary duty to clients.

Independent Managers may offer wrapped or non-wrapped pricing options. Wrap pricing structures
allow the client to pay an all-inclusive fee for management, brokerage, clearance, custody, and
administrative services.

A complete description of the programs and services provided, the amount of total fees, the payment
structure, termination provisions and other aspects of each Independent Manager are detailed and
disclosed in the Independent Manager’s disclosure brochure and other documents and agreements. A
copy of all relevant documents of the Independent Manager will be provided to clients that are
recommended to such Independent Manager.

Direct Fee Debit

Clients provide Position Wealth and/or certain Independent Managers with the authority to directly debit
their accounts for payment of the investment advisory fees. The qualified custodians that act as the
qualified custodian for client accounts, from 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 Position Wealth.

Use of Margin

Position Wealth may be authorized to use margin in the management of the client's investment
portfolio. In these cases, the fee payable will be assessed gross of margin such that the market value
of the client's account and corresponding fee payable by the client to Position Wealth will be
increased. Where investment management fees are assessed gross of margin, a conflict of interest
exists as the Firm has an incentive to use margin to increase its fees.

Account Additions and Withdrawals
...

Item 7 Types of Clients
Position Wealth offers services to individuals, high net-worth individuals, charitable organizations, and
corporations or other businesses.

Position Wealth has not established a minimum account size or a minimum advisory fee for services
to be rendered to a client.