Windsor Capital Management LLC

Item 5 Fees and Compensation
Portfolio Management Services
Our annual advisory fee for traditional portfolio management services consists of a asset-based
management fee, typically ranging between 0.35% and 1.00% of the value of your account. This
advisory fee is payable quarterly, in advance, based on the value of your account on the last day of the
previous calendar quarter. Our advisory fee is based on the total asset value of your account, which
includes the value of any accrued interest on individual fixed income positions within your portfolio.

If our traditional portfolio management services agreement is executed at any time other than the first
day of a calendar quarter, our fees will apply on a pro-rata basis, which means that our advisory fee is
payable only in proportion to the number of days in the calendar quarter for which you are a client. In
special cases, our fees and fee paying arrangements may be negotiable; therefore, arrangements with
existing clients may differ from that published in this firm brochure. In all cases, the final fee and billing
arrangements will be clearly set forth in the executed agreement for services.

We will either send you an invoice for the payment of our advisory fee, or your account custodian, as
paying agent for our firm, will deduct our advisory fee directly from your account. Our fee will be
deducted directly from your account only when (1) you have given our firm and your account custodian
written authorization authorizing the same, and (2) where your account custodian will deliver an
account statement to you at least quarterly showing all activity in your account, including, without
limitation, any direct debits of our advisory fees. You should review all account statements for
accuracy. We will also receive a duplicate copy of your account statements.

Our agreement for services will continue in effect until terminated by either party. You may terminate
the management agreement upon 30-days' written notice to our firm. You will incur a pro-rata charge
for services rendered prior to the termination of the agreement, which means you will incur advisory
fees only in proportion to the number of days in the calendar quarter during which you were a client.
Upon termination of our traditional portfolio management agreement, you will receive a pro-rated return
of any unearned fees to the date of termination.

For those clients who receive an invoice from our firm, we encourage you to reconcile our invoices with
the account statement(s) you receive from the qualified custodian of your assets. If you find any
inconsistent information between our invoice and the account statement(s) you receive from the
qualified custodian, please call our main office number located on the cover page of this firm brochure.

Advisory Consulting Services
Advisory consulting fees may consist of an asset-based fee, a fixed retainer fee, an hourly fee, or any
combination thereof. The type and amount of the fees charged will be negotiated on a case-by-case
basis. In the event you decide to engage our firm for advisory consulting services, you will be required
to enter into a written engagement letter with us describing the scope of the services to be provided
and the fees to be paid.

Either party may terminate the consulting engagement upon advance written notice to the other party.
Upon termination of the management agreement, you will receive a pro-rated return of any unearned
fees to the date of termination.

Advisory Services to Retirement Plans
Fees and fee paying arrangements for retirement plan services are negotiated on a case-by-case
basis. Where we provide continuous asset management services, our fees and fee paying
arrangements are based on the fee schedule and other information disclosed above for our traditional
portfolio management services.

Sub-Advisory / Co-Advisor Management Services
Where we are engaged for sub-advisory / co-advisory management services, Clients will pay our firm an
annual management fee ranging up to 0.35% of assets under management. Our advisory fee and
payment arrangements are negotiable depending on the needs of the Primary Investment Adviser and
their clients, which will be evidenced in a written agreement directly between our firm and the individual
client.

We will deduct our fee directly from the client account through the qualified custodian holding the
client funds and securities. Our fee will be deducted only where clients have provided such authorization
by signing an agreement with our firm and the appropriate custodial forms.

Either party may terminate the agreement upon 30-days' written notice to the other party.

Additional Fees and Expenses
In addition to, and exclusive of, our investment advisory fees disclosed above, you will also be charged
brokerage commissions, transaction fees, and other related costs and expenses for trade execution.
These transaction charges are paid to, and retained by, the account custodian for its clearance and
execution services. We do not receive any portion of these commissions, fees, or costs. For
information on our brokerage practices, please refer to Item 5 - Brokerage Practices of this firm
brochure.

As part of our investment advisory services to you, we may invest, or recommend that you invest, in
mutual funds, closed-end funds, individual fixed income and/or equity securities, and ETFs. The fees
that you pay to our firm for investment advisory services are separate and distinct from the fees and
expenses charged by mutual funds or ETFs (described in each fund's prospectus) to their
shareholders. These fees will generally include a management fee and other fund expenses. You will
also incur transaction charges and/or brokerage fees when purchasing or selling securities. These
charges and fees are typically imposed by the broker-dealer or custodian through whom your account
transactions are executed. We do not share in any portion of the brokerage fees/transaction charges
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Item 7 Types of Clients
We offer investment advisory services to individuals (including high net worth individuals), pension and
profit sharing plans, trusts, estates, charitable organizations, corporations, and other business entities.

For portfolio management accounts, we generally require the following minimums to open an maintain
an account with our firm: $200,000 for our fixed income style accounts; and $400,000 for our balanced
style accounts. At our discretion, we may waive the foregoing minimum account requirements. For
example, we may waive the minimum if you appear to have significant potential for increasing your
assets under our management, or where a smaller account is tied to a larger client relationship. We
may also combine account values for you and your minor children, joint accounts with your spouse,
and other types of related accounts to meet the stated minimum.

Where we may utilize the services of Altruist, in general, we do not require a minimum dollar amount to
open and maintain an advisory account; however, we have the right to terminate your Account if it falls
below a minimum size which, in our sole opinion, is too small to manage effectively.

Third party programs may have account minimums that are higher or lower than our minimum account
requirements. These minimums are disclosed separately in the relevant third party adviser's Form ADV
disclosure brochure, if any. Please refer to Item 12 - Brokerage Practices for additional disclosures.