ACAP Asset Management Inc

Item	5:	Fees	&	Compensation

Compensation	for	Our	Advisory	Services

Asset	Management:

                      Assets	Under	Management	              Annual	Percentage	of	Assets	Charge
                            $0	to	$2,500,000	                                1.00%
                       $2,500,001	to	$5,000,000	                            0.75	%
                            Over	$5,000,001	                                 0.50%

The	maximum	annual	fee	charged	for	this	service	will	not	exceed	1.00%.	Fees	to	be	assessed	will	be
outlined	in	the	advisory	agreement	to	be	signed	by	the	client.	Annualized	fees	are	billed	on	a	pro-rata
basis	quarterly	in	arrears	based	on	the	value	of	the	account(s)	on	the	last	day	of	the	quarter.	Fees	are
negotiable	and	will	be	deducted	from	client	account(s).	In	rare	cases,	our	firm	will	agree	to	directly
invoice.	As	part	of	this	process,	Clients	understand	the	following:

       a) Clients	 must	 provide	 our	 firm	 with	 written	 authorization	 permitting	 direct	 payment	 of
               advisory	 fees	 from	 their	 account(s)	 maintained	 by	 a	 custodian	 who	 is	 independent	 of	 our
               firm;
       b) Our	firm	sends	quarterly	statements	to	the	client	showing	the	fee	amount,	the	value	of	the
               assets	upon	which	the	fee	is	based,	and	the	specific	manner	in	which	the	fee	is	calculated	as
               well	as	disclosing	that	it	is	the	client’s	responsibility	to	verify	the	accuracy	of	fee	calculation,
               and	that	the	custodian	does	not	determine	its	accuracy;	and

ADV	Part	2A	–	Firm	Brochure	                        Page	6	                               ACap	Asset	Management,	Inc.

         c) The	account	custodian	sends	a	statement	to	the	client,	at	least	quarterly,	showing	all	account
            disbursements,	including	advisory	fees.

     Financial	Planning	&	Consulting:

     Our	firm	charges	on	a	flat	fee	basis	for	financial	planning	and	consulting	services.	The	total	estimated
     fee,	as	well	as	the	ultimate	fee	charged,	is	based	on	the	scope	and	complexity	of	our	engagement	with
     the	client.	The	starting	rate	for	flat	fees	is	$3500.	The	firm	collects	100%	of	payment	upfront.	AAM
     will	not	require	a	retainer	exceeding	$500	when	services	cannot	be	rendered	within	6	months.

     Retirement	Plan	Consulting:

     Our	Retirement	Plan	Consulting	services	are	billed	on	an	hourly	or	flat	fee	basis	or	a	fee	based	on	the
     percentage	 of	 Plan	 assets	 under	 management.	 The	 total	 estimated	 fee,	 as	 well	 as	 the	 ultimate	 fee
     charged,	 is	 based	 on	 the	 scope	 and	 complexity	 of	 our	 engagement	 with	 the	 client.	 The	 maximum
     hourly	fee	to	be	charged	will	not	exceed	$350.	Our	flat	fees	range	from	$3500	to	$10,000.	The	fee-
     paying	arrangements	will	be	determined	on	a	case-by-case	basis	and	will	be	detailed	in	the	signed
     consulting	agreement.

     Other	Types	of	Fees	&	Expenses

     Clients	 will	 incur	 transaction	 charges	 for	 trades	 executed	 by	 their	 chosen	 custodian.	 These
     transaction	 fees	 are	 separate	 from	 our	 firm’s	 advisory	 fees	 and	 will	 be	 disclosed	 by	 the	 chosen
     custodian.	 Clients	 may	 also	 pay	 holdings	 charges	 imposed	 by	 the	 chosen	 custodian	 for	 certain
     investments,	charges	imposed	directly	by	a	mutual	fund,	index	fund,	or	exchange	traded	fund,	which
     shall	 be	 disclosed	 in	 the	 fund’s	 prospectus	 (i.e.,	 fund	 management	 fees,	 initial	 or	 deferred	 sales
     charges,	 mutual	 fund	 sales	 loads,	 12b-1	 fees,	 surrender	 charges,	 variable	 annuity	 fees,	 IRA	 and
     qualified	retirement	plan	fees,	and	other	fund	expenses),	mark-ups	and	mark-downs,	spreads	paid	to
     market	makers,	fees	for	trades	executed	away	from	custodian,	wire	transfer	fees	and	other	fees	and
     taxes	on	brokerage	accounts	and	securities	transactions.	Our	firm	does	not	receive	a	portion	of	these
     fees.

     Termination	&	Refunds

     Either	party	may	terminate	the	agreement	at	any	time	by	providing	written	notice	to	the	other
     party.	Full	refunds	will	only	be	made	in	cases	where	cancellation	occurs	within	five	(5)	business
     days	of	signing	the	Adviser’s	Investment	Advisory	Agreement.	After	five	(5)	business	days,	Client
     will	receive	pro-rata	refund,	which	takes	into	account	work	completed	by	the	Adviser	on	behalf	of
     the	Client.	The	Client	will	incur	charges	for	bona	fide	Advisory	services	rendered	to	the	point	of
     termination	and	such	fees	will	be	due	and	payable	by	the	Client.	Refunds	will	be	given	on	a	pro-rata
     basis.

     Financial	 Planning	 &	 Consulting	 clients	 may	 terminate	 their	 agreement	 at	 any	 time	 before	 the
     delivery	of	a	financial	plan	by	providing	written	notice.	For	purposes	of	calculating	refunds,	all	work
     performed	by	us	up	to	the	point	of	termination	shall	be	calculated	at	the	hourly	fee	currently	in	effect.
     Clients	will	receive	a	pro-rata	refund	of	unearned	fees	based	on	the	time	and	effort	expended	by	our
     firm.

     Either	 party	 to	 a	 Retirement	 Plan	 Consulting	 Agreement	 may	 terminate	 at	 any	 time	 by	 providing
     written	notice	to	the	other	party.	Full	refunds	will	only	be	made	in	cases	where	cancellation	occurs

     ADV	Part	2A	–	Firm	Brochure	                       Page	7	                              ACap	Asset	Management,	Inc.

within	 5	 business	 days	 of	 signing	 an	 agreement.	 After	 5	 business	 days	 from	 initial	 signing,	 either
party	must	provide	the	other	party	30	days	written	notice	to	terminate	billing.	Billing	will	terminate
30	days	after	receipt	of	termination	notice.	Clients	will	be	charged	on	a	pro-rata	basis,	which	takes
into	account	work	completed	by	our	firm	on	behalf	of	the	client.	Clients	will	incur	charges	for	bona
fide	advisory	services	rendered	up	to	the	point	of	termination	(determined	as	30	days	from	receipt
of	said	written	notice)	and	such	fees	will	be	due	and	payable.

Item	7:	Types	of	Clients	&	Account	Requirements

Our	firm	has	the	following	types	of	clients:
     • Individuals	and	High	Net	Worth	Individuals;
     • Trusts,	Estates	or	Charitable	Organizations;
     • Pension	and	Profit	Sharing	Plans;

Our	firm	does	not	impose	requirements	for	opening	and	maintaining	accounts	or	otherwise	engaging
us.