Valorem LLC

Item 5 – Fees and Compensation

The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
agreement with the Advisor.

A. Fees for Advisory Services
Wealth Management Services
Wealth management fees are paid in advance of each calendar quarter, pursuant to the terms of the wealth
management agreement. Wealth management fees range from $15,000 to $20,000 annually based on several
factors, including: the scope and complexity of the services to be provided; the level of assets to be managed; and
the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements,
portfolio restrictions and other complexities may be charged a higher fee.

The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the
end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. All securities held in accounts
managed by Valorem will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the
Custodian’s valuation to ensure accurate billing.

The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other
related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor
shall not receive any portion of these commissions, fees, and costs.

Use of Independent Managers – As noted in Item 4, the Advisor will implement all or a portion of a Client’s investment
portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn
any compensation from an Independent Manager. The Advisor will only earn its wealth management fee as described
above. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 3.00%
of the Client’s assets under management annually.

                                                          Valorem LLC
                                       551 Madison Avenue, 12th Floor, New York, NY 10022
                                     Phone: 917-837-8846 | Website: https://valoremwealth.com/

Investment Consulting Services
For investment consulting engagements that fall outside of the Advisor’s wealth management services, the Advisor
will charge an investment consulting fee payable in advance of each quarter, pursuant to the terms of the investment
consulting agreement. Investment consulting fees are charged an annual asset-based fee of up to 0.50%, based on
the assets under advisement at the time of engagement. Fees may be negotiable depending on the nature and
complexity of the services to be provided and the overall relationship with the Advisor. An estimate of total costs will
be outlined in a separate investment consulting agreement prior to engaging for these services.

B. Fee Billing
Wealth Management Services
Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at
the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted
from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by taking the
annual fee divided by 4. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting
deduction of the wealth management fee. Clients are urged to also review and compare the statement provided by
the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees.
Clients provide written authorization permitting wealth management fees to be deducted by Valorem to be paid
directly from their account[s] held by the Custodian as part of the wealth management agreement and separate
account forms provided by the Custodian.

Use of Independent Managers – For Client accounts implemented through an Independent Manager, the Client’s
overall fees may include Valorem’s wealth management fee (as noted above) plus investment management fees
and/or platform fees charged by the Independent Manager[s], as applicable. In certain instances, the Independent
Manager or the Advisor may assume responsibility for calculating the Client’s fees and deduct all fees from the
Client’s account[s].

Investment Consulting Services
Investment consulting fees for ongoing engagements are due and payable in advance of each quarter. Clients may
choose to be invoiced directly, or have their fees deducted from a non-qualified investment account managed by the
Advisor, as applicable.

C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Valorem, in connection with investments
made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees
charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities
transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and
conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds
and other types of investments. The fees charged by Valorem are separate and distinct from these custody and
execution fees.

In addition, all fees paid to Valorem for investment advisory services are separate and distinct from the expenses
charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in
each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds,
other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible
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Item 7 – Types of Clients

Valorem offers investment advisory services to individuals and high net worth individuals. Valorem generally does
not impose a minimum relationship size.