Blue Water Capital Management, LLC

Blue Water Capital Management, LLC, established in 2007, offers asset management services, including discretionary asset management and ERISA plan services. The firm provides financial planning and consulting, seminars, and workshops. Clients must meet a minimum account size of $50,000, which may be lowered or waived in certain cases. Fees for asset management are based on a tiered structure, with annual fees ranging from 0.50% to 1.55% based on assets under management. Blue Water does not charge performance-based fees. The firm uses fundamental, quantitative, and qualitative analysis, asset allocation, and mutual fund/ETF analysis in its investment strategies. Blue Water does not engage in proprietary trading and does not receive soft dollar benefits. The firm reviews client accounts quarterly and provides written account statements at least quarterly. Blue Water has a Code of Ethics to address conflicts of interest and a fiduciary duty to act in the best interest of clients. The firm does not receive economic benefits from external sources and does not recommend securities in which it has a material financial interest. Blue Water has not been involved in any criminal or civil actions or administrative enforcement proceedings. The firm votes proxies for client accounts and retains records of proxy voting. Blue Water has no financial conditions impairing its ability to meet commitments to clients and has not filed any bankruptcy petitions in the past ten years.