Zephyr Investment Management Inc

Item 5 –Fees and Compensation
We will also provide consulting services to you if you
desire a review of a specified area, but do not wish to               Fees for Investment Management Services
engage us for investment management services.
These services are not considered financial planning             Required by §260.235.2 Code of California Regulation:
services because we will not perform a
                                                                    “A conflict exists between the interests of the investment
comprehensive analysis of your financial position.
                                                                    adviser or associated persons and the interest of the
                                                                    client; the client is under no obligation to act upon the
        Retirement Plan Consulting Services                         investment      adviser's    or    associated     person's
We offer retirement plan consulting services to                     recommendation; if the client elects to act on any of the
defined contribution retirement plans (the “Plan(s)”)               recommendations, the client is under no obligation to
                                                                    effect the transaction through the investment adviser,
and to the Plan’s named fiduciary (the “Plan
                                                                    the associated person when the person is an agent with
Sponsor”). These services are offered on a non-                     a licensed broker-dealer or through any associate or
discretionary investment basis.                                     affiliate of such person. Lower fees for comparable
                                                                    services may be available
Investment Adviser 3(21) Fiduciary Services: We shall
serve as an “Investment Adviser” and a
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                                                                       statement your custodian sends to you and verify the
from other sources. Our fee is calculated based upon the               calculation of our fees. Your custodian does not verify
market value of the assets in your account on the last                 the accuracy of fee calculations, but we test for
day of the previous quarter. We do not receive any                     accuracy of fees charged. If you choose to be billed for
additional compensation directly from advisory                         our services, we will bill you in advance, meaning
accounts beyond the advisory fee described above.                      that we will bill you before we have provided our
However, our advisory representatives may receive                      services to you. Our fee will be based upon the value
commissions and other compensation in their                            of your account as of the last business day of the
separate capacities as registered representatives of a                 preceding quarter. Our initial fee will be pro-rated
broker-dealer or insurance agents, as described                        based upon the number of days in the quarter that we
below. One-fourth of our annual fee is charged each                    provided advisory services to you. All fees are due
calendar quarter in advance.                                           within 20 days of the invoice date. If your payment is
                                                                       not received within 45 days, the custodian will
Broker-dealers and other financial institutions that                   withdraw the fees directly from your account as
hold client accounts are referred to as custodians.                    indicated in your advisory agreement.
Your custodian determines the values of the assets in
your portfolio. Fees for the initial quarter are based                 We will send a statement to you that includes the
upon the value of your account on the date the                         value of your investments, the amount of the
custodian receives them. Those fees are pro-rated                      advisory fee we charged, and how our fee was
based upon the number of calendar days in the                          calculated. You should review our calculations to
calendar quarter that our agreement is in effect.                      ensure that they appear accurate.
The fee schedule for Investment Management                             In addition to our advisory fees, you may be
Services is described below:                                           required to pay other charges, such as custodial
                                                                       fees; brokerage commissions; transaction fees;
            Assets under Management                                    maintenance and termination fees for IRAs and
                  Advisory Fee                                         certain retirement and qualified accounts; internal
                                                                       fees and expenses charged by mutual funds or
            First $250,000   1.50%                                     ETFs; and other fees and taxes on brokerage
            Next $500,000    1.25%                                     accounts and securities transactions. Mutual fund
            Next $500,000    1.00%                                     companies and ETFs charge internal fees and
            Over $1,250,000+ Negotiable                                expenses for their products. These fees and
All fees are negotiable at our sole discretion.                        expenses are in addition to any advisory fees
                                                                       charged by us. Complete details of these internal
You may elect to either have our advisory fees directly                fees and expenses are explained in the prospectuses
...

Item 7 – Types of Clients                               own proprietary indicators. BCAM seeks to
                                                                   enhance asset appreciation and reduce risk by
We provide advisory services primarily to                          increasing or decreasing the amount of assets
individuals, high net worth individuals and families,              placed in multiple investment categories. Our goal
including their trusts, estates and retirement accounts.           is to focus your account in those sectors/asset
We also provide services to corporations or business               classes that we believe show the potential for
entities, including their pension and profit- sharing              appreciation and avoid those that we believe show
plans. As a condition for starting and maintaining an              the potential for lower value.
advisory relationship, our minimum initial
investment requirement is $250,000.                                Although we use models as the foundation for
                                                                   investment decisions, your specific account will be
We, at our sole discretion, may permit you to establish            managed based on your individual financial
accounts with initial investment amounts less than this            circumstances, investment objectives, and risk
minimum. We make this determination based upon                     tolerances. We may periodically adjust your
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account (a process referred to as “rebalancing”) to               other things) loss of principal, a reduction in earnings
help ensure that your investment account remains                  (including interest, dividends and other distributions),
consistent with your objectives, goals, and risk                  and the loss of future earnings. Our investment
tolerances.                                                       strategies may include long-term and short-term
                                                                  purchases and sales, and trading. As previously noted,
We select specific investments for your account                   you may place reasonable restrictions on the strategies
using fundamental analysis, cyclical analysis and                 to be employed and the types of investments to be
technical(charting) analysis.                                     held in your account.

Fundamental analysis is a method of evaluating
several characteristics of the investments we                     Impact of Tariffs on Investments Risk: Investing in
recommend (e.g., mutual funds, ETFs or variable                   markets affected by tariff policies carries
annuity sub-accounts), including, among others,                   significant risks that may negatively impact the
investment objectives (e.g., growth, income, capital              value of investments. The U.S. President has the
preservation); investment type (e.g., large cap value             authority to impose, increase, or modify tariffs on
stocks, small cap growth stocks, bonds); past                     imports and exports, which can lead to higher costs
performance; management tenure; fees and other                    for businesses, supply chain disruptions, and
expenses; and holdings.                                           retaliatory trade measures from other countries.
                                                                  Tariffs may cause:
Cyclical analysis is a form of fundamental analysis                 Increased costs for companies reliant on
that evaluates the various stages of the economic                       imported       goods,   potentially    reducing
cycle. Decisions regarding whether to purchase or                       profitability.
sell particular investments are made based on how                   Market volatility as investors react to trade
those investments perform during economic                               uncertainties.
downturns and upswings. We closely monitor the
                                                                    Reduced global trade activity, impacting
level, direction and rate of change of a wide variety of
                                                                        economic growth and corporate earnings.
economic variables so that we can determine where
we are in a given cycle.                                            Sector-specific disruptions, particularly in
                                                                        industries heavily dependent on international
Technical analysis is a method of evaluating activity,                  supply        chains     (e.g.,     technology,
such as the price movement and trading volume of                        manufacturing, agriculture). There is no
various market indices. As technical analysts we do                     certainty regarding the duration, scope, or
not attempt to measure an investment’s intrinsic                        future changes to tariff policies, which may
value, but instead use charts and other tools to                        create      an     unpredictable     investment
identify patterns that can suggest future performance.                  environment. Investors should consider the
                                                                        potential impact of tariffs on specific
Charting involves identifying patterns in the prices of                 industries and the broader economy when
investments and market indices that can suggest future                  making investment decisions.
activity in price movements. A chart pattern is a
distinct formation that provides an indicator of future
price movements. Chartists use these patterns to                       Item 9 – Disciplinary Information
identify current trends and trend reversals that can
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