Twelve Points Wealth Management LLC

Item 5: Fees and Compensation

Twelve Points Portfolio Plan: The Plan offers investors the opportunity to obtain
professional investment services and brokerage services for one all-inclusive fee (“wrap
fee”) based on assets under management. The wrap fee is an asset-based fee which includes
the management fee paid to the Firm for its services as portfolio manager, as well as broker-

Form ADV Part 2A: Investment Adviser Brochure                                                     Page 10
Twelve Points Wealth Management LLC

dealer, custodial and clearing expenses. The complete fee schedule for the Portfolio Plan
is available in our Wrap Fee Program Brochure. The fee schedule is as follows:

                           Assets Under Management        Annual Fee (%)

                           Under $5,000,000               1.00%/Negotiable

                           $5,000,001 - $15,000,000       0.60%/Negotiable

                           Over $15,000,001               0.40%/Negotiable

Additional details on the Firm’s wrap fee program can be found in the annexed Wrap Fee
Program Brochure. The Firm maintains a minimum asset level of $500,000 and a minimum fee
level of 1.00%.

Clients who engage the Firm are charged an asset management fee of 50 basis points
(0.50%) for U.S. Treasury Bill securities.

Retirement Plan Advisory Fees. The Firm charges an asset-based fee for its retirement
plan advisory services according to the fee schedule below. The fee structure is expressed
on an annualized basis and fees are charged in advance based on the market value of assets
on the last trading day of each calendar quarter. In any partial calendar quarter, fees are
pro-rated based on the number of days in which the account is open during the quarter.

                                   Plan Assets ($)                 Fee (%)1,2
                      Up to $1,000,000                        0.500%
                      $1,000,001 to $5,000,000                0.400%
                      $5,000,001 to $10,000,000               0.250%
                      $10,000,001 to $20,000,000              0.200%
                      $20,000,001 to $50,000,000              0.100%
                      $50,000,001 to $100,000,000             0.050%
                      $100,000,001 to $500,000,000            0.025%
                      $500,000,001 to $1,000,000,000          0.010%
                      Over $1,000,000,001                     Negotiable

Custodian Charges - Additional Fees. As discussed below at Item 12 below, when
requested to recommend a broker-dealer/custodian for client accounts, the Firm generally
recommends that Schwab, Fidelity, or Goldman Sachs serve as the broker-dealer/custodian
for client investment management assets. Broker-dealers such as Schwab, Fidelity, and
Goldman Sachs charge brokerage commissions, transaction, and/or other type fees for

    Minimum annual fee: $5,000

    Maximum annual fee: $250,000

Form ADV Part 2A: Investment Adviser Brochure                                                 Page 11
Twelve Points Wealth Management LLC

effecting certain types of securities transactions (i.e., including transaction fees for certain
mutual funds, dealer spreads, and mark-ups and mark-downs charged for fixed income
transactions, etc.). The types of securities for which transaction fees, commissions, and/or
other type fees (as well as the amount of those fees) shall differ depending upon the broker-
dealer/custodian. While certain custodians, including Schwab, Fidelity, and Goldman
Sachs, generally (with exceptions) do not currently charge fees on individual equity
transactions (including ETFs), others do. There can be no assurance that Schwab, Fidelity,
or Goldman Sachs will not change its transaction fee pricing in the future. Please Note:
Schwab, Fidelity, and Goldman Sachs may also assess fees to clients who elect to receive
trade confirmations and account statements by regular mail rather than electronically.

Fee Dispersion. The Firm, in its discretion, may charge a lesser investment advisory fee,
charge a flat fee, waive its fee entirely, or charge fees on a different interval, based upon
certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets,
dollar amount of assets to be managed, related accounts, account composition, complexity
of the engagement, anticipated services to be rendered, grandfathered fee schedules,
employees and family members, courtesy accounts, competition, negotiations with client,
etc.). Please Note: As a result of the above, similarly situated clients could pay different
fees. In addition, similar advisory services may be available from other investment advisers
for similar or lower fees. ANY QUESTIONS: The Firm’s Chief Compliance Officer,
David Clayman, is available to address any questions that a client or prospective
client may have regarding advisory fees.

The Firm and/or you may terminate the account agreement, in whole or in part, at any time
with 30 days written notice. Upon termination, any fees paid in advance will be prorated
to the date of termination and any excess shall be refunded to you. Your advisory agreement
with the Firm is non-transferable without your written approval.

Margin Accounts: Risks. The Firm does not recommend the use of margin for investment
purposes. A margin account is a brokerage account that allows investors to borrow money
to buy securities and/or for other non-investment borrowing purposes. The
broker/custodian charges the investor interest for the right to borrow money and uses the
securities as collateral. By using borrowed funds, the customer is employing leverage that
will magnify both account gains and losses. Please Note: The use of margin can cause
significant adverse financial consequences in the event of a market correction. ANY
QUESTIONS: Our Chief Compliance Officer, David Clayman, is available to address
...

Item 7: Types of Clients

The Firm provides investment advisory services to individuals, pension and profit sharing
plans, trusts, corporations, accredited investors, family offices and high net worth
investors.