Holistic Capital – Fee Billing & Valuation Policy

1. Purpose

• This policy establishes the methodology Holistic Capital LLC uses to calculate, invoice,

and disclose client fees in compliance with SEC and state regulations. It also clarifies

how valuations are determined for billing purposes and how fee-related disputes are

handled.

2. Fee Schedule

• Holistic Capital charges the following fees, as outlined in the firm's Form ADV and Table

of Fees for Service:

• - Assets Under Management (AUM) Fee:

• • 1.00% on the first $1 million

• • 0.90% on the next $2 million

• • 0.75% on the next $2 million

• • 0.50% on assets over $5 million

• - Hourly Fee: $250–$500/hour for financial planning services

• - Fixed Fee: $1,000–$5,000 per engagement

• - Other Fees: Negotiable for educational events, seminars, or workshops

3. Valuation Methodology

• For AUM-based billing, Holistic Capital values client assets using the account balance as

reported by the custodian on the last business day of the billing period.

• If the account is managed through a third-party manager or robo-adviser, Holistic

Capital relies on the value reported by that platform.

4. Billing Frequency and Method

• AUM-based fees are billed quarterly in arrears.

• Hourly and fixed fees are invoiced as billed or upon completion of the service.

• Invoices may be delivered via email or client portal. Fees may be deducted from the

client’s investment account with prior authorization or paid directly by check or ACH.

5. Proration and Account Adjustments

• Fees for new clients are prorated from the date assets are initially placed under

management.

• For terminated accounts, fees are prorated through the termination date and any

prepaid fees are refunded.6. Third-Party Manager and Platform Fees

• Clients may be responsible for fees charged by third-party money managers and robo-

advisers used to implement investment strategies. These fees are billed directly by the

third party.

• Holistic Capital discloses these fees in advance and does not retain any portion of them.

7. Additional Client Costs

• Clients may incur other fees not paid to Holistic Capital, such as:

• - Brokerage fees (paid to custodian/broker-dealer)

• - Custodian fees (for account maintenance)

• - Mutual fund or ETF internal expense ratios

• Holistic Capital receives no commissions, mark-ups, or soft dollars.

8. Error Correction and Disputes

• If a billing error occurs, Holistic Capital will promptly correct the error and refund any

overcharged amounts.

• Clients may dispute fees in writing within 30 days of receipt of the invoice. Disputes are

handled promptly and documented in the client file.

9. Review and Updates

• This policy is reviewed annually and updated as needed to reflect changes in the firm's

fee structure or regulatory environment.

• Last Reviewed: 5.22.25