Spirit West Advisors LLC

Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
 ASSET MANAGEMENT

                                      Spirit West Advisors, LLC

 SWA offers discretionary asset management services to advisory clients. SWA is acting as
 the asset manager. The fees for these services will be based on a percentage of Assets
 Under Management as follows:
            Assets Under Management                       Annual Fee       Quarterly Fee
                 First $1,000,000                           1.55%            0.3875%
    Next $1,000,000 ($1,000,001 to $2,000,000)              1.35%            0.3375%
       Subsequent amounts ($2,000,000+)                     1.15%           0. 2875%
 This is a tiered/blended fee schedule, the asset management fee is calculated by applying
 different rates to different portions of the portfolio. SWA may group certain related Client
 accounts for the purposes of achieving the minimum account size and determining the
 annualized fee.

 For example (based on a quarterly billing period):
 Client with $2,500,000 under management would pay $8,687.50 on a quarterly basis.
              AUM                  Quarterly fee         Total
              First $1,000,000     x 0.3875% =           $3,875.00
              Next $1,000,000      x 0.3375% =           $3,375.00
              Next $500,000        x 0.2875% =           $1,437.50
              Grand total for the quarter                $8,687.50
 The annual fee may be negotiable. Accounts within the same household may be combined
 for a reduced fee. Fees are billed quarterly in advance based on the amount of assets
 managed as of the close of business on the last business day of the previous quarter.
 Quarterly advisory fees deducted from the clients' account by the custodian will be
 reflected on the quarterly statement. Lower fees for comparable services may be available
 from other sources. Clients may terminate their account within five (5) business days of
 signing the Investment Advisory Agreement without penalties or fees. Clients may
 terminate advisory services with thirty (30) days written notice. Client will be entitled to a
 pro rata refund for the days service was not provided in the final quarter. Client shall be
 given thirty (30) days prior written notice of any change in fees, and client will
 acknowledge, in writing, any agreement of change in said fees.
Client Payment of Fees
 Investment management fees are billed quarterly, in advance, meaning that we charge you
 before the three (3) month billing period has ended. Payment in full is expected within ten
 (10) days following the conclusion of the calendar quarter which the account is being billed
 for. Fees are usually deducted from a designated client account to facilitate billing. The
 client must consent in advance to direct debiting of their investment account.
Additional Client Fees Charged
 Custodians may charge transaction fees on purchases or sales of certain mutual funds,
 equities, and exchange-traded funds. These charges may include mutual fund transactions
 fees, postage and handling and miscellaneous fees (fee levied to recover costs associated
 with fees assessed by self-regulatory organizations).
 SWA, in its sole discretion, may charge a lesser investment advisory fee 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.).

                                     Spirit West Advisors, LLC

 For more details on the brokerage practices, see Item 12 of this brochure.
Prepayment of Client Fees
 SWA does not require any prepayment of fees of more than $1,200 per Client and six
 months or more in advance.
 Investment management fees are billed quarterly in advance.
 If the Client cancels after five (5) business days, any unearned fees will be refunded to the
 Client, or any unpaid earned fees will be due to SWA.
External Compensation for the Sale of Securities to Clients
 Managing Member Kevin M. Schaefer has a financial affiliated business as an insurance
 agent with Spirit West Certified Planning, LLC. Approximately 50% of his time is spent on
 this activity. From time to time, he will offer clients services from this activity. As an
 insurance agent, he may receive separate yet typical compensation.
 This practice represents a conflict of interest because it gives Mr. Schaefer an incentive to
 recommend products based on the commission amount received. This conflict is mitigated
 by disclosures, procedures, and the firm’s fiduciary obligation to place and act in the best
 interest of the client at all times. Clients always have the right to act on any insurance
 recommendations, and if they do decide to act have the right to do so with the insurance
 agent of their choosing.

Item 7: Types of Clients
Description
 SWA generally provides investment advice to individuals and high net worth individuals.
 Client relationships vary in scope and length of service.
Account Minimums
 SWA requires a minimum of $100,000 of household investable assets to open an account,
 but the firm does have the discretion to accept accounts with less assets.