SB Advisory LLC

Item 5 – Fees and Compensation

            The following sections provide details on fees and compensation of the various programs and
            services offered by SB Advisory, LLC.

            PORTFOLIO MANAGEMENT PROGRAMS

                                            Total Annualized fee charged to the client

                                             Up to $500,000                          2.50%1
                                        $500,000 up to $1 Million                    2.00%
                                       $1 Million up to $2 Million                   1.75%
                                       $2 Million up to $5 Million                   1.50%
                                           $5 Million and up                         1.25%

            Fees are payable monthly or quarterly in advance and are negotiable. Currently there is no
            account minimum for this program.

            Transaction Fees: Ticket charges/transaction fees may be negotiable at the time Client sets up their account
            for accounts in the RBC program. In some accounts, Clients may negotiate whether their IAR incurs ticket
            charges/transaction fees on their behalf. When Client pays the ticket charge, this fee is often marked up
            above the rate charged by RBC for the transaction, resulting in additional revenue to SB Advisory, LLC’s
            affiliated broker-dealer that acts as introducing broker-dealer to accounts custodied at RBC. This creates a
            conflict of interest to trade more in these Client accounts, as it generates more revenue to SB Advisory,
            LLC’ affiliate. When Client’s IAR agrees to incur tick charges on Client’s behalf, this creates a conflict of
            interest to reduce trading in the Client’s account, as the IAR will reduce its costs when doing so.

            Listed Equities: Up to $10 per transaction (buy & sell)

            Mutual Funds: $Up to $15 per transaction (buy & sell)

            Fixed Income: $Up to $20 per transaction (buy & sell)

                      *Lower fees for comparable services may be found from other sources.

            The annual fees provided above are payable in advance on a quarterly basis. The initial fee will
            be based on the value of assets at the inception of Client's program account(s) and then quarterly
            thereafter based upon the value of the client's account at the last business day of the preceding
            calendar quarter. The initial fee will be due upon inception. For accounts established in the first
            or second month of a quarter, the amount due is prorated for the remainder of the quarter. For

    Fees above 2% are higher than what is normally charged by investment advisers.

            accounts established in the third month of a quarter, the amount due will include the prorated
            amount for the remainder of the quarter as well as fees for the next quarter. The Client authorizes
            the Asset Management Services department of RBC to debit fees for the Client's account(s) under
            management by the Advisor.

            If the Client or Advisor wishes to terminate their relationship with the Advisor or Client,
            respectively, written notice shall be provided by the Client to the Advisor, or vice-versa. Said
            termination shall be effective immediately upon receipt of the termination notice by the other
            party. Client's death shall not terminate the authority granted to the Advisor hereunder until the
            Advisor has received actual notification of said death. Any fees for Services paid in advance for
            which Services have not been rendered will be refunded on a pro-rated basis.

            Advisory accounts at RBC
            The Client will be assessed the following annual fees. The following fees are negotiable between
            the Advisor and Client; however, no fee may exceed the stated level below listed.

                      Portfolio Value                 Fee
                      Up to $500,000                  2.50%2
                      $500,000 up to $1               2.00%
                      Million
                      $1 Million to $2 Million        1.75%
                      $2 Million to $5 Million        1.50%
                      $5 Million and up               1.25%

             *Lower fees for comparable services may be found from other sources.

            The annual fees provided above are payable in advance monthly. The initial fee will be based on
            the value of assets at the inception of Client's program account(s) and then monthly thereafter,
            based upon the value of the Client's account at the last business day of the preceding calendar
            month.

            Should the initial or a subsequent contribution of assets take place during a month, the fee for
            such contribution will be prorated for the remainder of the month and will be due within a
            reasonable period upon request. The initial fee will be due upon inception. For accounts
            established during a month, the amount due is prorated for the remainder of the month. The
            Client authorizes the custodian to debit fees for the Client's account(s) under management by the
            Advisor.

            In addition to the annual fees state above, the Client may incur additional charges from the
            broker/dealer and custodian. Such fees include, but are not limited to, commission charges,
            account maintenance fees, safekeeping fees, administrative fees, transfer fees, and transaction
            expenses, such as ticket charges and mailing and posting charges.

            When SB Advisory, LLC’s affiliate, San Blas Securities, acts as introducing broker-dealer for the
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Item 7 – Types of Clients

SB Advisory provides investment advisory services and investment advice to individuals, high
net worth individuals, and businesses. The Advisor at its discretion may provide investment
advisory services on a going forward basis to entities and programs, such as pension and profit-
sharing plans, Taft- Hartley plans, charitable institutions, foundations, endowments,
municipalities, registered mutual funds, trust programs, sovereign funds, foreign funds such as
UCITs and SICAVs, and other and international institutions.

As discussed above in Section 4, account minimums have been established to be eligible to
participate in certain programs. These minimums are:

     • AssetMark ($25,000 - $50,000 for mutual funds and $100,000 for ETFs)
     • Brinker Capital ($50,000)
     • Financial Planning Programs – no minimums