Description of Services and Fees Benchmark Capital Group Ltd. is a registered investment adviser based in Galena, Illinois. We are organized as a corporation under the laws of the State of Illinois. The firm also has a branch office in Edwardsville, IL. We have been providing investment advisory services since 1995. David Swisher is our principal owner. Currently, we offer the following investment advisory services, which are personalized to each individual client:
• Portfolio Management Services
• Financial Planning and Consulting Services The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words “we”, “our” and “us” refer to Benchmark Capital Group Ltd. and the words “you”, “your” and “client” refer to you as either a client or prospective client of our firm. Also, the term Associated Person is used throughout this brochure. As used in this brochure, our Associated Persons are our firm’s officers, employees, and all individuals providing investment advice on behalf of our firm. Portfolio Management Services We offer discretionary and non-discretionary portfolio management services. Our investment advice is tailored to meet your needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information at the beginning of our advisory relationship. We will use the information we gather to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf. As part of our portfolio management services, we may customize an investment portfolio for you in accordance with your risk tolerance and investing objectives. We may invest your assets according to one or more model portfolios developed by our firm. Once we construct an investment portfolio for you, or select a model portfolio, we will monitor your portfolio’s performance on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. Some degree of planning, as described below, is inherent to the overall asset management process. Unless otherwise engaged separately, written plans will not be delivered to and additional planning fees will not be charged to "management only" clients. Typically, such planning services would be purely incidental to the management process. However, extraordinary research or analysis may involve additional costs, which would be negotiated on an individual basis prior to beginning such work. Our annual fee for asset management services is subject to negotiation based on the amount of assets to be managed. The annual fee will not exceed 1.0% of the average daily balance of the assets under management. The annual fee shall be prorated and paid quarterly, in arrears, based on the average daily balance of the assets under management during the previous quarter. Alternatively, a fixed quarterly fee may be negotiated based on the amount of assets to be managed. All agreed upon fees and payment arrangements will be clearly stated in the advisory agreement executed between you and our firm. If the portfolio management 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 the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Our advisory fee is negotiable, depending on individual client circumstances. Typically, we require a minimum account size of $150,000 to open and maintain an asset management account. In our sole discretion, we may waive or lower such minimum. In addition, at our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in your paying a reduced advisory fee based on the available breakpoints in our fee schedule stated above. We will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when the following requirements are met:
• You provide our firm with written authorization permitting the fees to be paid directly from your account held by the qualified custodian.
• We send you an invoice showing the amount of the fee, the value of the assets on which the fee is based, and the specific manner in which the fee was calculated. The account value reported by your custodian on your quarterly statements may differ from the account value we use to calculate our fee due to differences in reporting settlement dates for transactions in your account(s).
• The qualified custodian agrees to send you a statement, at least quarterly, indicating all amounts dispersed from your account including the amount of the advisory fee paid directly to our firm. You may terminate the portfolio management agreement upon written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the portfolio management agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. We encourage you to reconcile our invoices with the statement(s) you receive from the qualified custodian. If you find any inconsistent information between our invoice and the statement(s) you receive from the qualified custodian please call our main office number located on the cover page of this brochure. If you have any questions regarding such variations, please contact your investment adviser representative. Business Retirement Plans The Adviser provides consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include: investment options, plan structure and participant education. Business Retirement Plan Fees We charge as a percentage of assets within the retirement plan not to exceed .85%. The fee-paying arrangements for retirement consulting service will be determined on a case-by-case basis and will be detailed in the signed retirement plan agreement. The client is assessed a fee per the agreement the client signs with the third party recordkeeper. Financial Planning Services We offer broad-based, modular, and consultative financial planning services. Financial planning will typically involve providing a variety of advisory services to you regarding the management of your financial resources based upon an analysis of your individual needs. If you retain our firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. Once we specify those long-term objectives

(both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm we provide you with a plan of action and estimates of the fees for financial planning services. Further meetings will be conducted as needed. We will analyze the collected data to produce a plan that is designed to achieve your expressed financial goals and objectives. We may be engaged to complete one or more elements of a personal or business financial plan, including, but not limited to the following:
• Budgeting and Cash Flow Analysis: Preparation of a detailed budget and cash flow analysis.
• Income Tax Planning: Preparation of detailed tax advice and recommendations related to capital gains tax issues relevant to your investment portfolio, including generic investment recommendations. You must review any such advice with your accountant or tax attorney prior to implementation.
• Education Planning: Preparation of a detailed financial plan, including generic investment recommendations, relating to the funding of educational expenses for you or your children or other dependents.
• Retirement Planning: Preparation of a detailed financial plan, including generic investment recommendations, dealing with your financial concerns relating to retirement.
• Estate Planning: Preparation of a detailed financial plan, including generic investment recommendations, dealing with your financial concerns relating to the final disposition of your estate.
• Investment Analysis Planning: Preparation of a detailed analysis of your current financial situation and a detailed financial plan, including generic investment recommendations, based upon this analysis.
• Fringe Benefit Analysis: Preparation of a detailed analysis, including generic investment recommendations, of the fringe benefits offered by you, if you act as an employer, or received by you, if you act as an employee.
• Quarterly Financial Reviews: Quarterly reviews of your investments. The review will involve generic investment recommendations. Such analyses will be based upon the information provided to us by you and if applicable, our independent research. Certain assumptions may be made with respect to interest and inflation rates and the use of past trends and performance of the market and economy. Past performance is not an indication of future results. We cannot offer any guarantees or promises that your financial goals and objectives will be met. As your financial situation, goals, objectives, or needs change, you must promptly notify us. On occasion, we provide general non-securities advice on topics that may include tax planning, budgetary planning, estate planning, business planning, retirement planning, and/or fringe benefit analysis. Financial planning and/or consulting services fees will be based on an hourly negotiable fee of $85 per hour. Planning fees are typically due monthly and will be billed in arrears. If we also manage your accounts, the planning fees can be drafted from the managed account as described above. In extraordinary circumstances and/or for lengthy engagements, we may require that a portion of the estimated fee be paid in advance. Fees and payment arrangements will be clearly stated in the agreement executed between us. Factors that are considered when determining the hourly fee, include but are not limited to:
• The scope of the plan, i.e., plans that cover all aspects of your financial plan such as business succession, estate planning, retirement needs, education planning, and successor trusts, among others, would warrant a higher fee than a more simplistic situation covering typical financial needs for current money management and retirement.
• Complexity of your financial situation, i.e., trusts, estates, business ownership, tax brackets, and other personal needs. The time/cost will vary from client to client. In limited circumstances, the time/cost could potentially exceed the initial estimate. In such cases, we will notify you and may request that you pay an additional fee. Under no circumstances will we require prepayment of a fee in excess of $1,200 and for more than six months in advance. In our sole discretion, we may waive, lower, or offset a portion of the financial planning fee in lieu of a portion of the management fee if you utilize our asset management services, as more fully described above. However, you may act on our recommendations by placing securities transactions with any brokerage firm you choose. You are under no obligation to act on our financial planning recommendations. Moreover, if you elect to act on any of the recommendations, you are under no obligation to implement the financial plan through our firm. If you only require advice on a single aspect of the management of your financial resources, we offer modular financial planning and/or general consulting services that address only those specific areas of concern. Our hourly fee for general consulting services is $85.00 per hour. Generally, these consulting services consist of verbal advice rather than a written financial plan. This fee is due and payable in full upon completion of the consultation. The services to be provided, associated fees, and payment arrangements are negotiable and will be detailed in the agreement executed between us. Planning and consulting services are also offered on an on-going annual basis. As part of this annual retainer program, we will generally establish a regular planning cycle to work with you in managing specific aspects of the overall financial plan that are unique to your situation. Additionally, we may meet with your other professional advisers (financial, legal, real estate, tax, etc.) for a series of information gathering and/or implementation meetings. We will act as a project manager to coordinate the work of the appropriate parties in a manner consistent with your long-term desired outcome. As your financial situation, goals, objectives, or needs change, you must promptly notify us. We do not provide legal or tax preparation services. Fees charged by other professionals for such services are separate and distinct from planning fees paid to us. Typically, other professionals will bill you directly. However, where you ask us to engage other professionals on your behalf, these other professionals will bill us and, in turn, we will bill you for additional costs incurred. However, this arrangement will not cause you to pay professional or advisory fees in excess of normal fees typically charged by either party. We will not share in any portion of the fees paid to other professionals on your behalf. The agreed upon hourly retainer fee and payment arrangements will be established at the beginning of the advisory relationship based upon the scope of the work to be performed and the complexity of your financial situation. You may terminate the financial planning agreement by providing notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the agreement. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees. Wrap Fee Programs We do not participate in any wrap fee program. Types of Investments We offer advice on equity securities, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities, and options contracts on securities. Additionally, we may advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing. Assets Under Management As of December 31, 2023, we manage $146,321,051 in client assets on a discretionary basis and $3,140,569 in client assets on a non-discretionary basis for a total of assets under management of $149,461,620.