S Williams Capital LLC

Item 5. Fees and Compensation

Investment Management Fee:

      1.0% annual (0.25% quarterly) management fee
Management fees are deducted from the client’s account by the qualified custodian with written
client authorization. Management fees are calculated as a percentage of the daily account value
on the last trading day of each calendar quarter and are payable at the end of each quarter.
Management fees depend upon and incorporate the value of all assets in the account for the
immediately prior quarter. Management fees are prorated for any contributions or withdrawals
made during a calendar quarter.
SWC may, in its sole discretion, waive all or any portion of the management fee.
Other Fees and Expenses:
In addition to the management fee described above and, for qualified clients, the performance-
based fee described below, all third-party fees (e.g., borrowing costs on securities sold short,
brokerage fees, custodian fees, interest on margin accounts, mutual fund fees, trading
commissions, transaction fees, wire transfer fees, etc.) are payable by the client. Third-party fees
are separate and distinct from the fees charged by SWC.
Please see Item 12 Brokerage Practices for additional information.

Neither SWC nor its supervised persons accept any compensation for the sale of securities or other
investment products.

Item 7. Types of Clients

SWC provides discretionary investment advisory services to both individuals and high net worth
individuals. The minimum required to open an account is $50,000, subject to waiver, reduction,
or increase at SWC’s discretion.
SWC manages funds contributed by its principal and related persons. SWC believes this approach
best aligns the interests of SWC and its clients.