Shelton Wealth Management LLC

Item 5 – Fees and Compensation

How We Are Compensated for Our Advisory Services

The specific manner in which fees are charged and calculated are described in your investment
advisory agreement. You should carefully review the investment advisory agreement prior to

signing it. Our fees vary among the different types of advisory services we offer and may be
negotiated at our sole discretion. Fees for our advisory services may be higher than fees charged by
other advisers who offer similar services. You may be charged different fees than similarly situated
clients for the same services. We can have varied legacy fee schedules and arrangements that it
honors for relationships that pre-date this disclosure brochure. You should carefully review this
brochure to understand the fees and other sources of compensation that exist among our services
prior to entering into an investment advisory contract with our firm.

Investment and Wealth Management Services

SWM offers investment and wealth management services for an annual fee based on the amount of
assets under the firm’s management. Fees are generally billed in advance each calendar quarter
based on the market value of the assets under management/advisement on the last day of the
previous calendar quarter. SWM, in our sole discretion, may waive the minimum annual fee based
upon certain criteria, including, but not limited to, anticipated future earning capacity and/or
additional assets, dollar amount of assets to be managed, related accounts, account composition,
pre-existing client relationships, account retention, and pro bono activities. For investment and
wealth management services SWM provides to certain clients or for specific client holdings (e.g.,
held-away assets, 529 plans, etc.), we may negotiate a fee rate that differs from our standard fee
schedule.

Annual advisory fees range up to 1.5% per annum and are negotiated based on the complexity of
the engagement and the assets under management prior to the start of the engagement. The
advisory fee is based on a percentage of the fair market value of the assets in the relevant
Account(s) and is calculated and charged on an account by account basis. While in most situations,
the advisory fee will be a flat percentage across all accounts (based on the aggregate value of all
household Accounts), in some cases we can agree to a reduced advisory fee percentage for one or
more particular Accounts. However, certain ERISA rules prevent householding corporate plans
with personal assets for fee reductions. You should refer to your advisory agreement for your
specific fee rate(s).

Programs Offered Through Wells Fargo Advisors

Fees for advisory programs offered through Wells Fargo Advisors are inclusive of SWM’s and Wells
Fargo Advisors’ advisory fees and are as follows:

 Program                 Program Type                Maximum Annual Advisory Fee
 Private Advisor         Separately Managed          $0 - $500,000: 1.75%
 Network                 Account                     Next $500,000: 1.50%
                                                     Next $4,000,000: 1.25%
                                                     Above $5,000,000: Negotiable

Wells Fargo Advisors will calculate and directly debit advisory fees from the clients’ accounts for
assets within their programs. The value of assets held in any Wells Fargo Advisor program are
excluded from the amount of total household assets used to determine SWM’s advisory fees for
other assets of a client that are managed by SWM.

Selection of Independent Managers

Fees for Independent Managers are set forth by the Independent Manager and are in addition to
SWM’s fees. You should refer to the Independent Manager’s investment management agreement
and Form ADV Part 2A Brochure for information on their fees and compensation.

Financial Planning and Consulting Services

Investment advisory clients retaining SWM will receive financial planning services as part of the
asset-based fee and will not pay additionally for this service. For stand-alone plans or services, fees
for financial planning and/or consulting services are billed on an hourly or fixed rate in advance.
Hourly fees generally range up to $400 per hour. There is no minimum fee required for financial
planning or consulting services; however financial planning and consulting fees shall generally not
exceed $20,000 annually. A retainer may be requested to start services and the remainder of fees
are due and payable as incurred.

Factors we consider when determining our financial planning and consulting fees include, but are
not limited to:

    •   The amount of time we expect to spend completing the financial planning or consulting
        services and providing related advice;
    •   The complexity of your goals, issues and/or needs;
    •   The extensiveness and complexity of the data needed regarding your personal financial
        information;
    •   Your net worth or the value of your investment accounts and/or other assets that are the
        subject of the financial planning or consulting services; and/or
    •   Special circumstances related to life changes, marital status, health or special income needs,
        or growth or decline of a personal business.

SWM may request a retainer to initiate financial planning and consulting services; however, we will
not request the prepayment of fees more than $1,200 in advisory fees more than six months in
advance.

You may engage SWM for additional investment management services to assist with implementing
one or more financial planning recommendations. You will incur additional fees if you retain our
firm for such services. You have complete freedom in selecting an investment adviser to assist you
in implementing any recommendations by SWM and are under no obligation to act upon the advice
we provide.

For consulting services, the agreement between SWM and the client will continue in effect until
...

Item 7 – Types of Clients

SWM provides portfolio management services to individuals, high net worth individuals and
families, trusts, estates, charitable institutions, foundations, corporations, and other business
entities.

SWM generally requires a minimum initial investment of $500,000 for investment management
services. The firm, in its sole discretion, may accept clients with smaller portfolios based upon each
client’s particular circumstances.

Certain Independent Managers may impose more restrictive account requirements and varying
billing practices than SWM. In such instances, SWM can alter its corresponding account
requirements and/or billing practices to accommodate those of the Independent Managers.