Stirlingshire RIA LLC

Item 5: Fees and Compensation

    A. Management Fees

             Type                                        Fee
             Portfolio Management Fees                   Assets Under Management (AUM) -
                                                         Annual Rates:
                                                         Asset Tier Annual Fee Rate
                                                         First $250,000                      2.00%
                                                         $250,001 - $500,000                1.75%
                                                         $500,001 - $1,000,000               1.50%
                                                         $1,000,001 - $3,000,000            1.25%
                                                         $3,000,001 - $5,000,000            1.00%
                                                         $5,000,001 - $10,000,000           0.75%
                                                         Over $10,000,000                   0.50%
                                                         Key Details:
                                                         • Blended Calculation: Fees are
                                                         calculated across all tiers based on total
                                                         AUM
                                                         • Monthly Billing: Billed monthly in
                                                         arrears based on average daily balance
                                                         Actual fees are documented in the
                                                         Advisory Agreement between
                                                         Stirlingshire and Client

    Stirlingshire’s	 portfolio	 management	 fees	 are	 negotiable	 up	 to	 2.00%	 of	 assets	 under
    management	as	such	fee	is	agreed	upon	by	the	adviser	and	client	in	relation	to	the	type
    of	account,	assets,	and	number	of	accounts	managed	by	Stirlingshire.

    Stirlingshire	uses	an	average	of	the	daily	balance	in	the	client's	account	throughout	the
    billing	period	to	determine	the	market	value	of	the	assets	on	which	the	advisory	fee	is
    based.

    Clients	may	terminate	the	investment	advisory	agreement	without	penalty	for	a	full	refund	 of
    Stirlingshire's	fees	within	five	(5)	business	days	of	signing	the	agreement.	Thereafter,	clients
    may	terminate	the	investment	advisory	contract	immediately	upon	written	notice.	Additional
    fees	 in	 relation	 to	 trade	 or	 account	 activity	 assessed	 by	 the	 brokerage	 firm	 or	 custodian
    holding	the	client's	accounts	are	not	included	in	the	portfolio	management	fee	or	the	 AIM
    model	 strategy	 fee	 (see	 below	 for	 more	 information).

    B. AIM Model Marketplace Fees

             Type                                        Fee
             AIM Model Strategy Fee, applicable to       Between 20 and 100 basis points, dependent
             assets invested in a model offered in the   on the model selected, broken down as
             AIM model marketplace                       follows:
                                                         AIM Access Fee for access to the model
                                                         marketplace: 20 Basis Points
                                                         Specific Model Strategy Fee: 0 – 80 Basis
                                                         Points

    The	specific	model	strategy	fee	is	determined	by	the	strategist	that	has	developed	the
    particular	model	and	made	it	available	in	the	AIM	model	marketplace.	The	AIM	model
    strategy	fee	is	the	total	of	the	AIM	access	fee	and	the	specific	model	strategy	fee	and	is
    applicable	to	the	assets	invested	in	a	particular	model.	AIM	uses	an	average	of	the	daily
    balance	in	the	client’s	account	throughout	the	billing	period	to	determine	market	value
    of	the	assets	on	which	the	model	strategy	fee	is	based.

    C. Payment of Fees

    Payment of Management Fees

    Portfolio	management	fees	are	paid	in	arrears	and	withdrawn	monthly	directly	from	each
    client's	account	as	authorized	by	the	client	in	their	investment	advisory	contract.

    AIM	model	strategy	fees	are	paid	in	arrears	and	withdrawn	quarterly	directly	from	each
    client’s	account	as	authorized	by	the	client	in	their	investment	advisory	contract.

    D. Client Responsibility for Third Party Fees

    Clients	 are	 responsible	 for	 the	 payment	 of	 all	 third-party	 fees	 (i.e.	 custodian	 fees,
    brokerage	 fees,	 platform	 fees,	 mutual	 fund	 fees,	 model	 strategy	 fees,	 transaction	 fees,
    etc.).	 Those	 fees	 are	 separate	 and	 distinct	 from	 the	 fees	 and	 expenses	 charged	 by
    Stirlingshire.	 Please	 see	 Item	 12	 of	 this	 brochure	 for	 further	 discussion	 regarding
    brokerage	and	custodian	fees.

    E. Prepayment of Fees

    Stirlingshire	collects	fees	in	arrears.	It	does	not	collect	fees	in	advance.

    F. Outside Compensation for the Sale of Securities to Clients

    1. Registered Representatives of SBD

      Certain	 individuals	 associated	 with	 Stirlingshire	 are	 registered	 representatives	 of	 an
      affiliated	 Broker-Dealer,	 Stirlingshire	 BD	 LLC	 (SBD).	 In	 this	 role,	 they	 receive
      compensation	including	commissions	for	the	sale	of	investment	products	to	Stirlingshire
      clients.	 Individuals	 associated	 with	 Stirlingshire	 are	 not	 required	 to	 also	 be	 registered
      representatives	of	SBD.	 Clients	may	identify	if	an	individual	is	also	associated	with	SBD	at
      FINRA	BrokerCheck.

          §   This is a Conflict of Interest
      Supervised	 persons	 may	 accept	 compensation	 for	 the	 sale	 of	 investment	 products,
      including	asset-based	sales	charges	or	service	fees	from	the	sale	of	mutual	funds	to
...

Item 7: Types of Clients

    Stirlingshire	provides	advisory	services	to	 individuals,	trusts,	and	entities.	There	is	no
    account	 minimum	 for	 our	 services.