XXI Wealth LLC

Item 5: Fees & Compensation

XXI Wealth offers services for an annual fee based on the amount of assets under the Firm’s
management or advisement. This management fee varies up to 150 basis points (1.50%),
depending upon the size and composition of a client’s portfolio, the type and amount of services
rendered and the individual(s) providing the services.

The annual fee is prorated and charged quarterly, in advance, based upon the market value of the
assets being managed by XXI Wealth on the last day of the previous quarter as determined by a
party independent from the Firm (including the client’s custodian or another third-party). If a
valuation for private securities is not available through the custodian, the Firm will typically rely on
the valuation provided by the issuer. Because valuations may only be provided periodically
(including monthly, quarterly, or even annually), the Firm can be billed on a valuation that would

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be different if updated. That valuation can be higher or lower depending on the increase or
decrease in value of the private investment.

The Firm includes cash in a client’s account in determining the valuation for billing purposes. The
Firm can, in its sole discretion, not include cash in determining the fee, especially when a client
has a high percentage of cash for reasons other than the Firm's investment management decision.

The Firm, at its discretion, can combine the account values of family members living in the same
household to determine the applicable advisory fee. For example, the Firm can combine account
values for the client and the client’s minor children, joint accounts with the client’s spouse, and
other types of related accounts. Combining account values can increase the asset total, which
can result in the client paying a reduced advisory fee should they reach an agreed upon
breakpoint.

Adjustments will be made for deposits and withdrawals during the quarter that are more than
$100,000. For the initial period of an engagement, the fee is calculated on a pro rata basis. In the
event the advisory agreement is terminated, the fee for the final billing period is prorated through
the effective date of the termination and the outstanding or unearned portion of the fee is charged
or refunded to the client, as appropriate.

For assets held at a custodian that is not directly accessible by the Firm ("Held Away Accounts"),
the Firm can, but is not required to, manage these Held Away Accounts using the Pontera Order
Management System ("Pontera") that allows the Firm to view and manage assets. The annual fee
for investment management services for held away accounts will be the same as the fees in the
Advisory Agreement. In those cases, however, the Firm’s advisory fees will not be deducted
directly from the accounts managed through the Pontera Order Management System. Clients will
give written authorization to deduct the fee from another non-qualified account managed by the
Firm, in which case, the advisory fee would be deducted from this account each quarter. The
client does not pay an additional fee for Pontera. The qualified custodian will deliver an account
statement to you at least quarterly that shows all disbursements from the accounts. Clients should
review all statements and invoices for accuracy. The Firm pays 0.25% from its advisory fee to
Pontera.

Fee Discretion

XXI Wealth can, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria,
such as anticipated future earning capacity, anticipated future additional assets, dollar amount of
assets to be managed, related accounts, account composition, pre-existing/legacy client
relationship, account retention, pro bono activities, or competitive purposes.

Additional Fees and Expenses

In addition to the advisory fees paid to XXI Wealth, clients 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 include securities
brokerage commissions, transaction fees, custodial fees, fees attributable to alternative assets,
fees charged by the third-party managers, margin and other borrowing costs, charges imposed
directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g.,

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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.

Fidelity Brokerage Services (“Fidelity”) eliminated transaction fees for U.S. listed equities and
exchange traded funds for clients who opt into electronic delivery of statements or maintain at
least $1 million in assets at Fidelity. Clients who do not meet either criteria will be subject to
transaction fees charged by Fidelity for U.S. listed equities and exchange traded funds.

Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction fees for U.S. listed equities
and exchange traded funds.

Dynasty Network Expenses
As discussed above in Item 4, we use Dynasty’s TAMP services. While the Dynasty Program Fee
is included in the annual investment management fee, the third-party manager related charges (if
applicable) are not included in the investment management fee you pay to us. Clients will be
charged, separate from and in addition to their investment management fee, any third-party
manager fees applicable. Our firm does not receive any portion of the fees paid directly to Dynasty
or the service providers made available through its platform, including the third-party managers.
...

Item 7: Types of Clients & Account Requirements

XXI Wealth offers services to individuals and high net worth individuals; trusts, estates or
charitable organizations; pension, retirement plans, and profit-sharing plans; corporations, limited
liability companies and/or other business types.

Minimum Account Value

As a condition for starting and maintaining an investment management relationship, XXI Wealth
imposes a minimum account balance of $1,000,000. XXI Wealth can, in its sole discretion, accept
clients with smaller portfolios based upon certain criteria, including anticipated future earning
capacity, anticipated future additional assets, dollar amount of assets to be managed, related
accounts, account composition, pre-existing client, account retention, and pro bono activities. XXI
Wealth only accepts clients with less than the minimum portfolio size if the Firm determines the
smaller portfolio size will not cause a substantial increase of investment risk beyond the client’s
identified risk tolerance. XXI Wealth can, in its sole discretion, aggregate the portfolios of family
members to meet the minimum portfolio size.