Rubicon Advisors GP

Item 5: Fees & Compensation

    Compensation for Our Advisory Services

    Comprehensive Portfolio Management:

    The maximum annual fee to be charged to the client’s account(s) will not exceed 1.75% The fee to be
    assessed to each account will be detailed in the client’s signed advisory agreement, LPL Account
    Application or LPL Tiered Fee Authorization form. The total estimated fee, as well as the ultimate fee
    charged, is based on the number of client’s asset managed by our firm as well as the scope and
    complexity of our engagement with the client. Fees are billed on a pro-rata basis quarterly in advance
    based on the value of the account(s) on the last day of the previous quarter. Fees are negotiable and
    will be deducted from the account(s). Please note that fees will be adjusted for deposits and
    withdrawals made during the quarter. If accounts are opened during the quarter, the pro-rata
    advisory fees will be deducted during the next regularly scheduled billing cycle. Our firm bills on cash
    unless indicated otherwise in writing. In rare cases, our firm will agree to direct bill clients. As part
    of this process, Clients understand the following:

         a) LPL as the client’s custodian sends statements at least quarterly, showing all disbursements
            for each account, including the amount of the advisory fees paid to our firm;
         b) Clients provide authorization permitting LPL to deduct these fees;
         c) LPL calculates the advisory fees for all fee schedules and deducts them from the client’s
            account.

ADV Part 2A – Firm Brochure                         Page 8                                           Rubicon Advisors

    LPL Sponsored Advisory Programs:

    The account fee charged to the client for each LPL advisory program is negotiable, subject to the
    following maximum account fees which includes the third-party manager fees:

                        Advisory Program                Annual Percentage of Assets Charge
                       Manager Access Select                       Up to 1.80%
                      Model Wealth Portfolio                       Up to 1.80%
                     Optimum Market Portfolio                      Up to 1.80%
                     Personal Wealth Portfolio                     Up to 1.80%
                      Guided Wealth Portfolio                      Up to 1.35%

    LPL has a separate billing process which we have no control over. In general, they will directly bill
    you and a portion of this fee will be paid to our firm and will be outlined their separate written
    disclosure documents.

    Financial Planning & Consulting:

    Our firm charges on an hourly or flat fee basis for financial planning and consulting services. The total
    estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our
    engagement with the client. The maximum hourly fee to be charged will not exceed $350. Flat fees
    will not exceed $5,000. The fee-paying arrangements will be determined on a case-by-case basis and
    will be detailed in the signed consulting agreement. Our firm will not require a retainer exceeding
    $1,200 when services cannot be rendered within 6 months.

    Retirement Plan Consulting:

    Our Retirement Plan Consulting services are billed on an hourly, flat fee basis, or a fee based on the
    percentage of Plan assets under management. The total estimated fee, as well as the ultimate fee
    charged, is based on the scope and complexity of our engagement with the client. The fee-paying
    arrangements will be determined on a case-by-case basis and will be detailed in the signed consulting
    agreement.

    Other Types of Fees & Expenses

    Non-Wrap Clients will incur transaction fees for trades executed by their chosen custodian, via
    individual transaction charges. These transaction fees are separate from our firm’s advisory fees and
    will be disclosed by the chosen custodian.

    LPL Financial’s trading platform (“SWM”) offers a variety of investments including, but not limited
    to, individual stocks, individual bonds, exchange traded funds (“ETFs”), and mutual funds. Over the
    course of the last twelve months, LPL Financial has made available to our firm a suite of $0
    transaction fee mutual funds and ETFs. As a SWM client, you are responsible for covering the
    transaction fee costs. Thus, these new offerings can potentially benefit you as you would no longer
    be paying transaction costs associated with each trade in those types of investments. However, the
    limited number of ETFs and mutual funds available to us may have higher overall expenses than other
    types of ETFs and mutual funds offered by LPL Financial. Therefore, while our firm considers
    transaction fees in its buying decisions, they are not our firm’s sole deciding factor. Our firm’s
    primary focus is what is in the best interest of the client and their portfolio. Thus, our firm will base
    our decisions on a number of factors including, but not limited to, the merits of the investments, how

ADV Part 2A – Firm Brochure                        Page 9                                          Rubicon Advisors

    that investment fits within your investment objectives, risk level, and your investment goals. We will
    also consider the overall fees of the investment, performance objectives of the investment, and actual
    investments within the particular ETF or mutual fund.

    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 and other fund expenses), initial or
    deferred sales charges, mutual fund sales loads, 12b-1 fees (in extremely rare cases when charged by
...

Item 7: Types of Clients & Account Requirements

    The advisory services offered by our firm 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.

    However, our firm generally provides investment advice to individuals and high net worth
    individuals. Our firm is currently not working with other types of clients or pursuing them as
    prospects, but would not turn away any opportunities that may arise.

    Our firm does not impose requirements for opening and maintaining SWM accounts or otherwise
    engaging with us. However, LPL Financial Sponsored Advisory Programs have the following account
    minimums:
       • Optimum Market Portfolios Program (OMP): $15,000
       • Personal Wealth Portfolios Program (PWP): $250,000
       • Model Wealth Portfolios Program (MWP): $25,000
       • Manager Access Select Program (MAS): $100,000 (in certain instances, the minimum account
           size may be lower or higher).
       • Guided Wealth Portfolio (GWP): $5,000

    For customized advisory services, any required minimum account value will be set out in the client
    agreement.