Spiegelman Wealth Management Inc

Item 5:       Fees and Compensation

      A. Fees Charged

      All investment management clients will be required to execute an Investment Advisory Agreement that will
      describe the type of management services to be provided and the fees, among other items.

      Generally, fees range from 1.35% to 0.45% per annum of the market value of a client’s assets managed by
      SWM. Our tiered fee schedule is below:

                                   Aggregate Account           Account Fee
                                          Size
                                   Above $10,000,000              0.45%
                                    Next $5,000,000               0.55%
                                    Next $3,000,000               0.70%
                                    Next $1,000,000               0.95%
                                     Next $500,000                1.10%

                                Next $250,000                1.25%
                                First $250,000               1.35%

The fee range stated is a guide. Fees are negotiable, and may be higher or lower than this range, based on the
nature of the account. Factors affecting fee percentages include the size of the account, complexity of asset
structures, and other factors. Please note that same or similar services may be available for a lower cost from
other investment advisers. Financial planning services are included in the investment management fee.

B. Fee Payment

Investment Advisory fees will generally be debited directly from each client’s account. As of the date of this
brochure, the advisory fees may be paid monthly, in arrears, and the fees shall be calculated monthly using
an average of the daily balance in the client's account throughout 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.

Clients whose fees are directly debited will provide written authorization to debit advisory fees from their
accounts held by a qualified custodian chosen by the client. The client will also receive a statement from their
account custodian showing all transactions in their account, including the fee.

C. Other Fees

There are a number of other fees that can be associated with holding and investing in securities. You will be
responsible for fees including transaction fees for the purchase or sale of a mutual fund or Exchange Traded
Fund, or commissions for the purchase or sale of a stock unless you are enrolled in the SWM Wrap Program.
Expenses of a fund will not be included in management fees, as they are deducted from the value of the shares
by the mutual fund manager. For complete discussion of expenses related to each mutual fund, you should
read a copy of the prospectus issued by that fund. SWM can provide or direct you to a copy of the prospectus
for any fund that we recommend to you. SWM may utilize external money managers, exchange traded funds,
mutual funds and other investment options. These investment options have related expenses which are not
included in the advisory fee. Clients utilizing SWM’s wrap fee portfolio management should see the separate
Wrap Fee Program Brochure for additional details regarding third party fees.

Please make sure to read Item 12 of this informational brochure, where we discuss broker-dealer and custodial
issues.

D. Pro-rata Fees

If you become a client during a billing cycle you will pay a management fee for the number of days left in that
cycle. You may terminate the Investment Management Agreement by providing written notice to SWM Once
your notice of termination is received, we will charge the fee through the date of transfer of your assets. SWM
will cease to perform services, including processing trades and distributions, upon termination. Assets not
transferred from terminated accounts within 30 (thirty) days of termination may be “de-linked”, meaning

      they will no longer be visible to SWM and will become a retail account with the custodian.

      E. Compensation for the Sale of Securities

      This item is not applicable. SWM does not receive any commissions or fees from investment product
      providers or custodians. Its sole source of income is from fees paid by clients.

Item 7:       Types of Clients

      Clients advised may include individuals, families, retirement accounts, trusts, foundations, and corporations.
      SWM does not currently require a minimum account size to receive our services.