Smith Capital Management Inc

Item 5: Fees and Compensation

revenue sharing fees and takes the receipt of such fees into consideration in terms of benefits it
may elect to provide to the firm, even though such benefits may or may not benefit some or all
of the firm clients.
Additional Disclosure Concerning Wrap Programs: To the extent that we either sponsor or
recommend wrap fee programs, please be advised that certain wrap fee programs may (i) allow
our investment adviser representatives to select mutual fund classes that either have no
transaction fee costs associated with them but include embedded 12b-1 fees that lower the
investor’s return (“sometimes referred to as “A-Shares,” depending on the mutual fund issuer),
or (ii) allow the use of mutual fund classes that have transaction fees associated with them but
do not carry embedded 12b-1 fees (sometimes referred to as “I-Shares,” depending on the
mutual fund sponsor). Wrap fee programs offer investment services and related transaction
services for one all-inclusive fee (except as may be described in the applicable wrap fee program
brochure). The trading costs are typically absorbed by the firm and/or the investment
representative. If a client’s account holds A-Shares within a wrap fee program, the firm and/or its
investment adviser representative avoids paying the transaction fees charged by other mutual
fund classes, which in effect decreases the firm’s costs and increases its revenues from the
account. Effectively, the cost is transferred to the client from the firm in the form of a lower rate
of return on the specific mutual fund. This creates an incentive for the firm or investment adviser
representative to utilize such funds as opposed to those funds that may be equally appropriate
for a client but do not carry the additional cost of 12b-1 fees. As a policy matter, the firm does
not allow funds that impose 12b-1 or revenue sharing fees on the client’s investment within its
wrap fee programs. Clients should understand and discuss with their investment adviser
representative the types of mutual fund share classes available in the wrap fee program and the
basis for using one share class over another in accordance with their individual circumstances
and priorities.

                    Part 2A of Form ADV: Smith Capital Management, Inc. Brochure

Item 7: Types of Clients
We provide our services to:
   ▪   Individuals, including high net worth individuals
   ▪   Pension and profit sharing plans
   ▪   Trusts, estates, or charitable organizations
   ▪   Corporations and other business entities (such as LLCs, LLPs, family limited partnerships)
   ▪   Pooled investment vehicles – private fund
We suggest (subject to negotiation) that a minimum account size to engage our services be at
least $500,000. To reach this threshold, accounts for one relationship may be “householded.”
Conditions and restrictions regarding the private fund are contained in the fund’s private
placement memorandum and subscription documents.

                   Part 2A of Form ADV: Smith Capital Management, Inc. Brochure