Sturman Wealth Advisors LLC

Item 5 – Fees and Compensation

The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more
written agreements with the Advisor.

A. Fees for Advisory Services
Wealth Management Services
Wealth management fees are paid monthly or quarterly (“Billing Period”) in advance of each calendar Billing Period
pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value
of assets under management at the end of the prior Billing Period. Wealth management fees range up to 1.75% annually
based on several factors, including: the scope and complexity of the services to be provided; the level of assets to be
managed; and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting
requirements, portfolio restrictions and other complexities may be charged a higher fee.

The wealth management fee in the first Billing Period of service is prorated from the inception date of the account[s] to
the end of the first Billing Period. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take
into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed
by Sturman Wealth will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the
Custodian’s valuation to ensure accurate billing.

The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other
related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor
shall not receive any portion of these commissions, fees, and costs.

Financial Planning Services
Sturman Wealth offers financial planning services as part of its overall wealth management services and fees.
Sturman Wealth also offers standalone financial planning services on an ongoing basis. Ongoing financial planning
fees range up to $7,500 per quarter. Fees may be determined based on the nature and complexity of the services to

                                                   Sturman Wealth Advisors
                                      404 People Place, Suite 404, Charlottesville, VA 22911
                                                      Phone: 434-201-2255
                                                https://www.sturmanwealth.com/

be provided and the overall relationship with the Advisor. An estimate for total costs will be determined prior to
engaging for these services.

Use of Independent Managers
As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio utilizing one or more
Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an
Independent Manager. The Advisor will only earn its investment advisory fee as described above. The Advisor may
allocate a portion of the advisory fee collected to the Independent Manager pursuant to the terms of the executed
agreement between the Advisor and the Independent Manager. The total blended fee, including the Advisor’s fee
and the Independent Manager’s fee, will not exceed 2.75% annually.

B. Fee Billing
Wealth Management Services
Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the
Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from
the Client’s account[s] at the beginning of the respective Billing Period. For Clients who are billed on a monthly basis,
the amount due is calculated by applying the monthly rate (annual rate divided by 12) to the total assets under
management with Sturman Wealth at the end of the prior month. For Clients who are billed on a quarterly basis, the
amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management
with Sturman Wealth at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from
the Custodian reflecting deduction of the wealth management fee. Clients are urged to also review and compare the
statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform
a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Sturman Wealth
to be paid directly from their account[s] held by the Custodian as part of the wealth management agreement and
separate account forms provided by the Custodian.

Financial Planning Services
Financial planning fees for ongoing engagements are invoiced quarterly in advance. Financial planning fees are paid
via check, credit card, or ACH.

Use of Independent Managers
For Client accounts implemented through an Independent Manager, the Advisor and the Independent Manager will
each assume the responsibility for calculating and deducting their respective fees from the Client’s account[s].

C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Sturman Wealth, in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities
execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge
securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms
and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds
and other types of investments. The fees charged by Sturman Wealth are separate and distinct from these custody
and execution fees.

In addition, all fees paid to Sturman Wealth for wealth management services are separate and distinct from the
...

Item 7 – Types of Clients

Sturman Wealth offers investment advisory services to individuals, high net worth individuals, trusts, and estates.
Sturman Wealth generally does not impose a minimum relationship size.