Sterling Investment Advisors Ltd

Item 5           Fees and Compensation

   A.
                                   INVESTMENT ADVISORY SERVICES
         The Registrant shall receive an investment advisory fee based upon a percentage (%) of
         the market value of the assets placed under management (between negotiable and 1.00%).

         The advisory fee will be pro-rated, and paid quarterly, in advance, based upon the market
         value of the assets on the last day of the previous quarter. Unless Registrant agrees
         otherwise, in writing, Registrant shall debit the account directly for its advisory fee. In
         the event of termination, Registrant shall refund any unearned portion of the advanced fee
         paid based upon the number of days remaining in the billing quarter. It is Registrant’s
         policy is to treat intra-quarter account additions and withdrawals equally, unless indicated
         to the contrary on the Registrant’s written Brochure and/or Investment Advisory
         Agreement executed by the client.

         Fee Differentials: Fees shall vary depending upon various objective and subjective
         factors, including but not limited to: the representative assigned to the account, the
         amount of assets to be invested, the complexity of the engagement, the anticipated
         number of meetings and servicing needs, related accounts, future earning capacity,
         anticipated future additional assets, and negotiations with the client. As a result, similar
         clients could pay different fees, which will correspondingly impact a client’s net account
         performance. Additionally, Registrant in its discretion, may charge a lesser investment
         advisory fee, charge a flat fee, waive its fee entirely, or charge fee on a different interval,
         based upon certain criteria (i.e., anticipated future earning capacity, anticipated future
         additional assets, dollar amount of assets to be managed, related accounts, account
         composition, complexity of the engagement, anticipated services to be rendered,
         grandfathered fee schedules, employees and family members, courtesy accounts,
         competition, negotiations with client, etc.).

         As result of the above, similarly situated clients could pay different fees. Moreover, the
         services to be provided by the Registrant to any particular client could be available from
         other advisers at lower fees. All clients and prospective clients should be guided
         accordingly.

         Additionally, clients who choose to engage Independent Manager(s) will incur a fee
         payable to the Independent Manager(s) that generally ranges between 0.50% and 1.00%
         of the value of the assets allocated to such Independent Manager(s). In such an event, the
         combined fee that a client will pay to the Registrant and the Independent Manager(s)
         generally falls within the fee range discussed above. Such combined fee shall not, at any
         time, exceed 1.00% of the market value of the assets under management.

                               RETIREMENT PLAN CONSULTING
    The Registrant also provides pension consulting services, pursuant to which it assists
    sponsors of self-directed retirement plans with the selection and/or monitoring of
    investment alternatives from which plan participants shall choose in self-directing the
    investments for their individual plan retirement accounts. The Registrant’s negotiable
    annual retirement consulting fee shall generally range between 0.06% and 0.75% of the
    market value of the plan assets.

           FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
    The Registrant provides financial planning and/or consulting services (including
    investment and non-investment related matters, including estate planning, insurance
    planning, etc.) on a stand-alone fee basis. Registrant’s planning and consulting fees are
    negotiable, but generally range from $2,000 to $20,000 on a fixed fee basis, or at a
    mutually agreed upon hourly rate, depending upon the level and scope of the service(s)
    required and the professional(s) rendering the service(s).

B. Clients may elect to have the Registrant’s advisory fees and financial planning fees
   deducted from their custodial account. Both Registrant's Investment Advisory Agreement
   and the custodial/ clearing agreement may authorize the custodian to debit the account for
   the amount of the Registrant's investment advisory fee and to directly remit that
   management fee to the Registrant in compliance with regulatory procedures. In the
   limited event that the Registrant bills the client directly, payment is due upon receipt of
   the Registrant’s invoice. The Registrant shall deduct fees and/or bill clients quarterly in
   advance, based upon the market value of the assets on the last business day of the
   previous quarter.

C. As discussed below, unless the client directs otherwise or an individual client’s
   circumstances require, the Registrant shall generally recommend that Charles Schwab
   and Co., Inc. (“Schwab”) serves as the broker-dealer/custodian for client investment
   management assets.

    Broker-dealers such as Schwab charge brokerage commissions, transaction, and/or other
    type fees for effecting certain types of securities transactions (i.e., including transaction
    fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income
    transactions, etc.). The types of securities for which transaction fees, commissions, and/or
    other type fees (as well as the amount of those fees) shall differ depending upon the
    broker-dealer/custodian. While certain custodians, including Schwab, generally (with the
    potential exception for large orders) do not currently charge fees on individual equity
    transactions (including ETFs), others do.
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Item 7           Types of Clients

         The Registrant’s clients shall generally include individuals, high net worth individuals,
         pension and profit-sharing plans, charitable organizations, and other business entities.
         Registrant does not impose a minimum asset requirement or a minimum fee requirement.