Sand Creek Capital LLC

Item 5: Fees and Compensation

A. Fee Schedule

Portfolio Management Fees

Clients have the option to pay fees based on a tiered fee schedule or a single rate of up to
2% for all assets under management. Final fees can be found on the client’s individual
investment advisory agreement.

The advisory fee is calculated using the value of the assets in the Account on the last
business day of the prior billing period.

Fees are negotiated between the client and the IAR. Account fees are payable monthly or
quarterly in advance or in arrears. The first payment will be based on the opening market
value of the account and will be pro-rated to cover the period from the date the account is
opened through the end of that calendar quarter. Thereafter, the fee will be based on the
account value on the last business day of the preceding calendar quarter. If client
contributes funds to their account on a date other than the first day on a calendar quarter,
then a prorated fee will be charged for that calendar quarter with respect to such
contribution based on the number of days remaining in that calendar quarter. If a client
withdraws assets on any date other than the last day of the calendar quarter, then a
prorated refund will be made based on the number of days left in the quarter prior to the
withdrawal.

These fees are generally negotiable, and the final fee schedule will be memorialized in the
client’s advisory agreement. Clients may terminate the agreement without penalty for a
full refund of SCC's fees within five business days of signing the Investment Advisory
Contract. Thereafter, clients may terminate the Investment Advisory Contract generally
with 30 days' written notice.

Payment of Subadviser Fees

Subadviser fees may be withdrawn from client’s accounts or clients may be invoiced for
such fees, as disclosed in each contract between AAA and the applicable third-party
adviser.

Pension Consulting Services Fees

Asset-Based Fees for Pension Consulting

Fees for pension consulting services are up to 1.50% of the plan assets for which SCC is
providing such consulting services. Account fees are payable monthly or quarterly in
advance or in arrears. For fees paid in advance, SCC uses the value of the account as of
the last business day of the billing period, after taking into account deposits and
withdrawals, for purposes of determining the market value of the assets upon which the
advisory fee is based. For fees paid in arrears, SCC uses an average of the daily balance in
the client’s account throughout the billing period, after taking into account deposits and
withdrawals, for the purpose of determining the market value of the assets upon which
the advisory fee is based.

These fees are generally negotiable, and the final fee schedule will be memorialized in the
client’s advisory agreement.

Clients may terminate the agreement without penalty for a full refund of SCC's fees within
five business days of signing the Investment Advisory Contract. Thereafter, clients may
terminate the pension consulting agreement generally with 30 days' written notice.

Financial Planning Fees

SCC does not charge separately for financial planning services.

Educational Seminar Fees
SCC may provide educational services at no additional cost or may charge a separate fixed fee
to the sponsoring organization or other third party. Any such fee is negotiated in advance and
is not based on the purchase or sale of securities, the number of participants, or advisory assets
under management.

B. Payment of Fees

Payment of Portfolio Management Fees

Asset-based portfolio management fees are withdrawn directly from the client's accounts
with client's written authorization on a monthly or quarterly basis . Fees may be paid in
arrears or advance, depending upon the custodian used.

Payment of Pension Consulting Fees

Asset-based pension consulting fees are withdrawn directly from the client's accounts
with client's written authorization on a monthly or quarterly basis. Fees may be paid in
arrears or advance, depending upon the custodian used.

Payment of Financial Planning Fees

SCC does not charge separately for financial planning services.

Payment of Education Seminar/Workshop Fees

Educational seminars and workshops may be offered at no cost or for a fixed fee, with any
applicable fee payable in advance and non-refundable.

C. Client Responsibility For Third Party Fees

Clients are responsible for the payment of all third-party fees (i.e., custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
distinct from the fees and expenses charged by SCC. Please see Item 12 of this brochure
regarding broker-dealer/custodian.

D. Prepayment of Fees

SCC collects certain fees in advance and certain fees in arrears, as indicated above.
Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis
and returned within fourteen days to the client via check or return deposit back into the
client’s account.

For all asset-based fees paid in advance, the fee refunded will be equal to the balance of
the fees collected in advance minus the daily rate* times the number of days elapsed in
the billing period up to and including the day of termination. (*The daily rate is calculated
by dividing the annual asset-based fee rate by 365.)

E. Outside Compensation For the Sale of Securities to Clients

Certain investment adviser representatives of SCC are also associated with LPL Financial
as broker-dealer registered representatives (“Dually Registered Persons”). In these roles,
they accept compensation for the sale of investment products to SCC clients.

1. This is a Conflict of Interest

   Certain investment adviser representatives of SCC are also associated with LPL
   Financial as broker-dealer registered representatives (“Dually Registered Persons”).
   In their capacity as registered representatives of LPL Financial, certain Dually
...

Item 7: Types of Clients

SCC generally provides advisory services to the following types of clients:

       ❖       Individuals
       ❖       High-Net-Worth Individuals
       ❖       Pension and Profit-Sharing Plans
       ❖       Corporations or Business Entities
       ❖       State or Municipal Government entities

There is no account minimum for any of SCC’s services.