SPG Advisors LLC

Item 5 - Fees and Compensation

Advisor Fees
Investment advisory and planning services fees are based on a percentage of Assets Under
Management at a rate of no more than 1.50% annually, including TPM fees. Lower fees for
comparable services may be available from other sources. The annual Fee may be negotiable.
Accounts within the same household may be combined for a reduced fee.

Depending upon perceived or anticipated market conditions/events (there being no guarantee
that such anticipated market conditions/events will occur), SPGA and/or engaged TPM may
maintain cash and cash equivalent positions (such as money market funds, etc.) for defensive,
liquidity, or other purposes. Unless otherwise agreed in writing, all such cash positions are
included as part of assets under management for purposes of calculating advisory fees. Cash
positions will be taken into account during the review of the client's portfolio, in accordance with
the guidelines stated in Item 13.

Billing Practices
Fees are assessed on a quarterly basis in advance based on the account value as of the last
day of the prior quarter. Initial fees are prorated and billed in arrears from the date of initial
investment to the end of that quarter based on the account value as of the last day of the initial
billing period.

The Client must consent in advance to direct debiting of their investment account. Quarterly
advisory fees deducted from the Clients' account will be reflected in the Client’s quarterly
custodial statement. We urge the Client to compare information in their Investment Advisory
Agreement with the fees listed in their custodial account statement.

Investment management fees are deducted from the Client’s account to facilitate billing. The
Client must consent in advance to direct debiting of their investment account.

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Form ADV2A                                                                  SPG Advisors LLC

Unless waived, standalone fees for financial plans are due upon delivery of the plan. SPGA will
send the plan to the Client concurrent with the request for payment or payment of the fee.

Clients may terminate advisory services with thirty (30) days written notice. The Client will be
entitled to a pro rata refund for the days service was not provided in the final quarter.

Co-Provider Fees
SPGA has entered into an agreement to utilize the services of a third-party money manager
Synergy Asset Management, LLC (“SAM”), as co-provider. SPGA and SAM will each receive a
fee for their services as Provider and Co-Provider, respectively.

 SPGA Advisors Provider Fees

 Assets Under Management                  Annual Fee                      Quarterly Fee

 $0 - $1,000,000                            1.00%                            0.25%

 $1,000,001 - $3,000,000                    0.50%                            0.125%

 Over $3,000,000                            0.25%                           0.0625%

 Synergy Asset Management Co-Provider Fees

 Assets Under Management                  Annual Fee                      Quarterly Fee

 $0 - $1,000,000                            0.45%                           0.1125%

 $1,000,001 - $3,000,000                    0.40%                            0.10%

 Over $3,000,000                            0.20%                            0.05%

SPGA in its sole discretion, may waive and/or reduce its portion of the advisory fee paid from
SAM based upon certain criteria (e.g., historical relationship, type of assets, anticipated future
earning capacity, anticipated future additional assets, dollar amounts of assets to be managed,
related accounts, account composition, negotiations with Clients, etc.).

DST Fees
With respect to Clients who establish new DST positions as of the Effective Date of this
Agreement, such DST positions will not be included in calculating SPGA’s or Synergy Asset
Management’s standard asset-based fees. Advisor and/or Synergy Asset Management will
determine to assess a separate and distinct fee for their advisory services pertaining to DST
investments based on a variety of factors such as, the size and complexity of the investment.
Any such DST fees and related fee terms will be agreed upon in writing with the DST investor
prior to or at the time of investment. The total DST fee, if any, may be split between SPGA and
Synergy Asset Management, which will be disclosed to the DST investor prior to or at the time

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Form ADV2A                                                                 SPG Advisors LLC

of investment. Neither SPGA’s nor Synergy Asset Management’s Clients are under any obligation
to consider or make an investment in a DST(s).

DST Conflicts of Interest
SPGA’s recommendations regarding DST investments could present material conflicts of
interest. For example, if SPGA recommends a DST investment, and assesses a DST fee that
exceeds the Client’s typical asset-based fee, this recommendation would present a conflict, as
SPGA would be incentivized to recommend the DST on the basis of increased advisory fees to
be received. Even if SPGA assesses a DST fee that is equal to or lower than the Client’s typical
asset-based fee, such recommendation could still present a conflict of interest, if DST fees were
accelerated into a one-time payment, as compared to an annual asset-based fee paid on a
quarterly basis. In addition, SPGA could be incentivized to recommend that a Client use assets
not subject to SPGA’s asset-based fee to fund a DST purchase, in that the recommendation
could be made in the interest of collecting a DST fee without diminishing the amount of assets
subject to SPGA’s asset-based fee. The material conflicts of interest associated with any
particular DST recommendation will be provided to the subject Client prior to or at the time of
recommendation. Clients are under no obligation to consider or make an investment in DST(s).
...

Item 7 - Types of Clients

SPGA generally provides investment advice to individuals and high net worth individuals. Client
relationships vary in scope and length of service. SPGA requires a minimum balance of
$500,000. However, SPGA reserves the right to waive or lower this requirement at its discretion.