SWBC Investment Company

Item 5 Fees and Compensation

SWBC Pricing Grid(s)
Fees for investment advisory services are a percentage of assets under management, assessed quarterly in
advance or arrears depending on the program type based on the accounts ending value at quarter end. Advisory
fees paid to SWBC are separate and distinct from other costs to the client such as brokerage commissions
and/or the costs inherent in co-mingled investment products such as mutual funds, regulatory fees and exchange
traded funds (i.e. expense ratios, etc.).

Fees are charged as a percentage of the assets under management, Fees are
separately disclosed within their Investment Advisory Agreement and can be
negotiated, however; the maximum fees are referenced below:
Asset Based Advisory Accounts
  Asset Value:                    Maximum Annual Fee           Maximum Quarterly Fee
  $ 0 to $ 249,999                 1.75%                        0.4375%
  $ 250,000 to $ 499,999            1.50%                        0.3750%
  $ 500,000 to $ 999,999            1.25%                        0.3125%
  $ 1,000,000 to $ 1,999,999        1.00%                        0.2500%
  $ 2,000,000 to $ 4,999,999        0.85%                        0.2125%
  $5,000,000 or more              Negotiated                   Negotiated

Fees are payable in advance or arrears depending on the program type utilizing the last day of prior reporting
period. Fees are negotiable. Fees will be pro-rated for time periods less than one quarter and adjusted for
capital flows into or out of an account. The fees charged by the Firm will be deducted from a client's account
by the account’s custodian and remitted directly to the Firm. The client will provide the custodian with written
instructions to accept, regard as accurate and to comply with the Firm’s instruction to remit payment for
services rendered. Reference WRAP Brochure for additional information.

Third Party Money Managers (“TPMM”)
SWBC makes available to over 200 TPMM strategies to which it may refer clients for investing; SWBC portfolio
managers are among the available options to serve as the TPMM. IARs will help the client select those programs
most suitable for the client’s stated financial goals within the client’s known risk tolerance. Clients whose accounts
are managed by SWBC on a non-discretionary basis (however very limited) should be aware that third-party
managers require authority to manage client accounts on a discretionary basis or account may be restricted or
closed. The third-party managers will establish their own fees and any requirements for minimum annual fees
and minimum account size, which may range up to $1,000,000.

Financial Planning Fee Schedule
$0.00 - $10,000.00 - Full Plan (determined by current plans in place and complexity of estate and assets) -
payable at the time of engagement. Plan will be delivered promptly, subject to the client’s delivery of the
necessary data for the plan.

$300.00 - minimum for modular plans - fully payable at the time of engagement.

$250.00 - $5,000.00 - Annual, semi-annual, quarterly, or monthly retainer for financial planning and consultation
services subject to Advisor/Client agreement. Hourly Planning Fee- $75.00 - $250.00 – subject to a 5 hour
retainer paid at the time of engagement.

These services will vary per the individual IAR and will be specified in a written agreement between the Firm
and the client prior to any services, specifying those services and the agreed-upon fee.

As a part of financial planning, certain IARs may also provide financial and investment advice in areas that are
not securities or investments. These may include aspects of estate and tax planning, realty / mortgage planning
and/or education planning.

The various portfolio money managers hired by third party service providers for its investment model platforms
may present different methods of analysis and may use different sources of information in selecting the
securities to construct the platform. SWBC’s IARs, in turn, review the portfolio structures assembled by those
third party managers for suitable application to the stated financial needs and goals of its own clients.

Either party to an advisory agreement for SWBC services may terminate that agreement with five (5) days’
written notice to the other. A pro-rata refund will be made of any pre-paid fees for termination prior to the end
of a period.

SWBC Institutional Advisory Services
From time to time, SWBC is engaged to provide Institutional Grade Investment-Only Asset Management
services ($5 million +) for a fee. Fees are calculated on a percentage of the size of the investment portfolio
value as either reported by an independent pricing service, custodian, bank or trust company, or as reported
by the client on its regulatory report (e.g. NCUA 5300 call report or similar report) and/or as otherwise agreed
upon between the adviser and the client. The fees change as the investment portfolio increases and decreases
asset size and may be incorporated into a Wrap Program or Non-Wrap Program.

SWBC’s maximum annual fees, based upon the total investment portfolio size under the advisory
agreement, are as follows:

          Investment Portfolio Value             Maximum Annual Fee
          Less than $25 million                  50.0 basis points
          $25,000,001 to $50,000,000             40.0 basis points
          $50,000,001 to $75,000,000             30.0 basis points
          $75,000,001 to $100,000,000            20.0 basis points
          $100,000,001 to $150,000,000           10.0 basis points
          More than $150,000,000                 8.0 basis points

Fees are negotiable on a case by case basis and may be lower than the maximum limit listed above. The fee
negotiated between the adviser and the client will vary based on the value, composition and complexity of the
assets under management and specific services provided the client.
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Item 7 Types of Clients
We provide investment advisory services to individuals, high net worth individuals, banking or thrift institutions,
charitable organizations and corporations or other businesses. We also act as an investment adviser to Private
Investment Funds. The underlying investors in the Private Investment Funds are typically accredited institutional
investors (e.g., trusts, endowments, foundations, corporations, banks, insurance companies, public and private
pension plans, private fund-of-funds, etc.), high net worth investors and employees, in each case, meeting the
applicable suitability requirements set out in the applicable Offering Documents of such Private Investment
Funds.

In general, we do not require a minimum dollar amount to open and maintain an advisory account; however,
we have the right to terminate your Account if it falls below a minimum size which, in our sole opinion, is too
small to manage effectively. TPMMs and third-party programs may impose a minimum account size or minimum
fee, which SWBC does not control, which may be as high as $1,000,000. Refer to the information found herein
regarding SWBC’s fees and expenses for serving as investment adviser. For the CPG Fund, the minimum
initial investment amount is generally $25,000; (but in each case, such minimum may be waived by SWBC).

SWBC and any of its supervised persons can accept compensation for the sale of securities or other investment
products, including asset-based sales charges or service fees from the sale of mutual funds, equities, insurance
products independent of its private fund offerings, reference additional information disclosed herein for conflicts
of interests. Certain SWBC associates receive compensation based in part on gross sales and assets under
management of SWBC’s accounts. This compensation received by those associates is structured so that it does
not incentivize the sale of any given product over another. Clients are under no obligation to purchase any
specific product from the Firm and/or its affiliates.

Clients should review all fees charged by SWBC, brokers, custodians, and others to fully understand the total
amount of fees incurred. Review the Fund prospectus or Firm brochure as applicable for information regarding
minimum investments and fees.