Tradewinds LLC

Item 5. Fees and Compensation
TradeWinds offers its services on a fee-only basis. Our fees will vary on the types of advisory services we offer
and may be negotiated at our sole discretion.

Investment Management Fee (also referred to as “Advisory Fee”)

TradeWind’s annual Advisory Fee is exclusive of, and in addition to, brokerage commissions, transaction fees,
and other related costs and expenses that are incurred by the client, as discussed below. TradeWinds does not,
however, receive any portion of these commissions, transaction fees, and costs. For investment and wealth
management services TradeWinds provides with respect to certain client holdings (e.g., held-away assets, 529

plans, etc.), we may negotiate a fee rate that differs from our standard fee schedule.

TradeWind’s annual advisory fee is based on the amount of assets under the Firm’s management. Fees are
generally billed monthly in arrears, based on average daily balance of the account(s) during the period.

Our fee schedule for Advisory services is as follows:

 Assets Under Management                                     Maximum Annual Advisory Fee
 $0 to $50,000                                               2.25%
 $50,001 to $3,000,000                                       1.75%
 $3,000,001 to $10,000,000                                   1.25%
 More than $10 million                                       Negotiable

This fee schedule may be based on cumulative household assets under management. However, certain ERISA rules
prevent householding corporate plans with personal assets for fee reductions. You should refer to your advisory
agreement for your specific fee rate(s).

Financial Planning Fees

TradeWind’s can charge a fixed fee for preparation of a financial plan, however we typically waive this fee for
all Wealth Management Clients. When not included in our asset management fee, the fees for financial
planning and/or consulting services can be billed on an hourly rate, fixed rate, or project basis in advance on a
monthly or quarterly basis. There is no minimum fee required for financial planning or consulting services; however
financial planning and consulting fees shall generally not exceed $20,000.

TradeWinds may request a retainer to initiate financial planning and consulting services. However, we will not
request the prepayment of fees more than $1,200 in advisory fees more than six months in advance.

Additional Fees and Expenses

In addition to the advisory fees paid to TradeWinds, clients may also incur certain charges imposed by other
third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions
(collectively “Financial Institutions”). These additional charges may include securities brokerage commissions,
transaction fees, custodial fees, charges imposed directly by a mutual fund or ETF in a client’s account as disclosed
in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees and other fees and taxes on brokerage
accounts and securities transactions. The Firm’s brokerage practices are described at length in Item 12, below.

Fee Debit

Clients generally provide TradeWinds with the authority to directly debit their accounts for payment of the
Firm’s investment advisory fees. The Financial Institutions that act as qualified custodians for client accounts have
agreed to send statements to clients not less often than quarterly detailing all account transactions, including any
amounts paid to TradeWinds. Alternatively, clients may elect to have TradeWinds send them an invoice for direct
payment.

Fees for Management During Partial Months of Service

For the initial period of investment management services, the fees are calculated on a pro rata basis. The Agreement
between TradeWinds and the client will continue in effect until terminated by either party pursuant to the terms
of the Agreement. TradeWind’s fees are prorated through the date of termination and any remaining balance
is charged or refunded to the client, as appropriate.

Clients may make additions to and withdrawals from their account at any time, subject to TradeWind’s right to
terminate an account. Additions may be in cash or securities provided that TradeWinds reserves the right to
liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients may
withdraw account assets on notice to TradeWinds, subject to the usual and customary securities settlement
procedures. However, TradeWinds designs its portfolios as long-term investments, and the withdrawal of
assets may impair the achievement of a client’s investment objectives. TradeWinds may consult with its clients
about the options and ramifications of transferring securities. However, clients are advised that when transferred
securities are liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e.
contingent deferred sales charge) and/or tax ramifications.

Item 7. Types of Clients
TradeWinds primarily provides its services to individuals, including high net worth individuals, certain retirement
plans, small businesses and corporations.