Tortuga Wealth Management Inc

Item 5: Fees & Compensation
Compensation for Our Advisory Services

Financial Planning & Consulting:

Our firm charges on an hourly or flat fee basis for financial planning and consulting services. The total
estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our
engagement with the client. The maximum hourly fee to be charged will not exceed $1,000. Flat fees
will not exceed $20,000. The fee-paying arrangements will be determined on a case-by-case basis
and will be detailed in the signed consulting agreement. Our firm will not require a retainer exceeding
$1200 when services cannot be rendered within 6 months.

LPL Financial Sponsored Advisory Programs:

    LPL Financial Sponsored Advisory Program               Annual Percentage of assets charged:

     Optimum Market Portfolios Program (OMP)                                 2.50%

     Personal Wealth Portfolios Program (PWP)                                2.50%

       Model Wealth Portfolios Program (MWP)                                 2.83%*

        Manager Access Select Program (MAS)                                  3.00%

The fees for LPL’s Financial Sponsored Advisory Programs are billed on a pro-rata annualized basis
quarterly in advance based on the value of your account on the last day of the previous quarter. LPL
Financial establishes and maintains their own separate billing process over which we have no
control. For more information regarding the LPL sponsored advisory programs, please see the LPL
Financial Form ADV Part 2 or applicable client agreement. LPL makes billing adjustments for deposits
and withdrawals within the quarter.

LPL Financial serves as program sponsor, investment adviser and broker-dealer for the LPL
Sponsored Advisory Programs. Our firm and LPL may share in the account fee and other fees
associated with program accounts.

* The MWP account fee consists of an LPL program fee, a strategist fee (if applicable) and an advisor
fee of up to 2.00%. Accounts remaining under the legacy fee structure may be charged one aggregate
account fee, for which the maximum account fee is 2.50%. See the MWP program brochure for more
information.

ADV Part 2A – Firm Brochure                    Page 7                             Tortuga Wealth Management

Other Types of Fees & Expenses

Non-Wrap Clients will incur transaction fees for trades executed by their chosen custodian, via
individual transaction charges. These transaction fees are separate from our firm’s advisory fees and
will be disclosed by the chosen custodian.

Clients may also pay holdings charges imposed by the chosen custodian for certain investments,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (e.g., fund management fees, distribution fees, surrender charges,
variable annuity fees, IRA and qualified retirement plan fees, mark-ups and mark-downs, spreads
paid to market makers, fees for trades executed away from custodian, wire transfer fees and other
fees and taxes on brokerage accounts and securities transactions). Our firm does not receive a
portion of these fees.

Wrap clients will not incur transaction costs for trades by their chosen custodian. More information
about this can be found in our separate Wrap Fee Program Brochure.

Termination & Refunds

Either party may terminate an LPL Financial Sponsored Advisory Program according to the terms of
the executed advisory contract. Upon receipt of your notice of termination, LPL will process a pro-rata
refund of the unearned portion of the advisory fees charged in advance at the beginning of the
quarter.

Financial Planning & Consulting clients may terminate their agreement at any time before the
delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work
performed by us up to the point of termination shall be calculated at the hourly fee currently in effect.
Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our
firm.

Commissionable Securities Sales

Representatives of our firm are also associated with LPL as broker-dealer registered representatives
(“Dually Registered Persons”). In their capacity as registered representatives of LPL, certain Dually
Registered Persons may earn commissions for the sale of securities or investment products that they
recommend for brokerage clients. They do not earn commissions on the sale of securities or
investment products recommended or purchased in advisory accounts through our firm. Clients have
the option of purchasing many of the securities and investment products made available through
another broker-dealer or investment adviser. When purchasing these securities and investment
products away from our firm, however, Clients will not receive the benefit of the advice and other
services we provide.

Item 7: Types of Clients & Account Requirements
Our firm typically services Individuals and High Net Worth Individuals;

ADV Part 2A – Firm Brochure                    Page 8                             Tortuga Wealth Management

Our requirements for opening and maintaining accounts or otherwise engaging us are defined above
in item 4 of this brochure.