Twin Lakes Capital Management LLC

ITEM 5: FEES AND COMPENSATION
Advisory Fees & Billing Practices
We receive an asset-based management fee based on the following fee schedule:

        Account Assets                      Quarterly Fee      Annual Fee
        On the first $3 million               0.3125%            1.25%
        On the next $7 million                0.2500%            1.00%
        On the next $10 million               0.1875%            0.75%
        On amounts over $20 million           0.1250%            0.50%

Negotiation is based on the account size and the scope and complexity of the services to be performed.
These fees are billed at the beginning of each quarter, based on the assets under management as of the last
day of the previous calendar quarter. These fees include financial planning services, when requested by
the client.

We have a conflict of interest when providing financial planning advice. When we negotiate our fees,
whether financial planning services will be included may be factored into the cost. You are not required
to employ us to implement the financial plan, or to implement the plan, or any portion of it, at all.

For qualified clients who participate in a private fund investment as described in Item 4, above, we will
receive an asset-based fee of 1% per annum, billed quarterly in advance based on the value of the
investment as reported by the investment fund. In addition, we will receive a performance fee of 10% of
the realized gains in the investment at the end of the investment. These fees are received only on the
portion of the account that is invested in the private fund. Performance fee arrangements could create an
incentive for us to recommend investments that are riskier or more speculative than would be the case in
the absence of the arrangement.

We generally request that you provide authorization for us to deduct our fees directly from your
investment account. Following is important information about the deduction of management fees:

        You must provide authorization for us to deduct fees by initialing the appropriate section of our
         contract.

        You will receive a detailed invoice each quarter which outlines our fees and how they are
         calculated at the same time we request payment from the custodian.

        You will receive a statement from your custodian which shows your all transactions in your
         account, including the deduction of our fees.

        You are responsible for reviewing the accuracy of the fees being billed, as the custodian will not
         do so.

You may elect to pay by check rather than having payment deducted directly from your account.

You may end our advisory relationship by providing 30 days written notice. We will prorate the advisory
fees earned through the termination date and send you a refund of the prepaid, unearned portion of your
fee. We process refund payments within 2 weeks of the termination date and will send you a check or

refund your investment account. In either case we will provide a final invoice detailing the calculation of
the refund.

Other Costs Involved
In addition to our advisory fee shown above, you are responsible for paying fees associated with investing
for your account. These fees include:

     mutual fund loads (if applicable). These charges are paid to brokers as a form of commission.

     management fees for ETFs and mutual funds. These are fees charged by the managers of the ETF
      or mutual fund and are a portion of the expenses of the ETF or mutual fund.

     brokerage costs and transaction fees for any securities or fixed income trades. These are
      generally charged by your custodian and/or executing broker.

     Fees paid to investment managers/funds to which we refer clients.

Additional information about brokerage costs and services is provided in “Item 12: Brokerage Practices.”

We believe the fees mentioned above are competitive; however you may be able to obtain similar services
from other sources at a lower price.

ITEM 7: TYPES OF CLIENTS
Our clients are typically individuals and families. Generally we require an initial investment commitment
of $3,000,000 of assets under management with us. However, we may waive that minimum at our sole
discretion.