Alooola LLC

Item 5 – Fees and Compensation

alooola, LLC Fee Programs.

The programs described above are tier based according to assets under management. alooola fees
for Individual and Plan accounts are as follows:

 Tier                         AUM                 Annual Client Fee

 Tier 1                       <$25,000            0.25% AUM plus admin
                                                  fee of $5 annually
 Tier 2                       >$25,000            0.50% of AUM plus
                                                  admin fee of $5 annually
 401(k)            Sponsor NA                     0.1%-1% per annum
 (Employer)

Clients may request to terminate their advisory contract with alooola, LLC, by providing 30
days advance written notice. The administrative fee is non-refundable for accounts that are closed for
any reason.

Clients may pay fees for services that they receive for their alooola accounts that are paid to entities
other than affiliates of alooola (e.g. clearing and custodial charges, maintenance and
termination fees, wire charges, etc.) that are in addition to alooola, LLC’s advisory fees. The
clearing firm may charge transaction fees for: odd lot differentials, transfer taxes, wire
transfer, ACAT transfers, electronic fund fees, paper statement and other related costs and
expenses. Mutual funds and exchange-traded funds also charge internal management fees
which are not paid to alooola or its affiliates, which are disclosed in each fund’s prospectus.

Should a client’s financial situation, investment needs, and/or risk tolerance lead
to recommendations for such products, the Adviser will seek to recommend appropriate products
that typically use a class of mutual fund shares designed for advisory accounts and generally does
not pay a 12b-1 service fee back to the Firm. However, the Firm may hold and/or add to legacy fund
positions that have a less advantageous expense structure. If mutual fund shares designed
for advisory accounts are not available or not used, the purchase will be done with no sales charge
regardless of the type of fund class used. Additionally, if any 12b-1 service fees are due from
a mutual fund for mutual funds held in an advisory account, the fees are received and credited to
the client's advisory account by the custodian.

        alooola, LLC                                                   Form ADV Part 2A

For portfolios structured as long-term investments, asset withdrawals may impair the achievement
of a client’s investment objectives. However, clients may make additions to and withdrawals from
their investment advisory account at any time, subject to alooola, LLC’s contractual right to
terminate an account or the Firm’s legal or regulatory obligation to freeze an account. As part of
alooola’s anti-money laundering procedures clients may be restricted from withdrawing funds that
alooola, in its sole discretion, believes the transfer may not be in compliance with alooola’s
customer agreements and/or in line with alooola’s AML policies. If such a restriction prohibits a
client from withdrawing funds, that client may withdraw account assets on notice to alooola, LLC,
subject to the satisfactory response to any additional questions or requests from the alooola
compliance department and the usual and customary securities settlement procedures. alooola and
or the custodian of client accounts reserve the right to require that funds leaving alooola accounts
return to their original source account According to alooola’s anti-money laundering
procedures clients may be restricted from withdrawing funds at any time.

Additions may be in the form of cash, cash equivalents, or securities provided that alooola,
LLC reserves the right to liquidate any transferred securities, or decline to accept particular
securities into a client’s account. alooola, LLC may consult with its clients about the options and
ramifications of transferring securities. However, clients are advised that when transferred
securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual
fund level (i.e. contingent deferred sales charge) and/or tax ramifications.

alooola, LLC, will not act as a custodian of the client’s accounts or perform any custodial services.
The client may terminate the alooola advisory contract at any time with the proper notice
period as identified in the investment advisory contract.

401k Employer Billing

401k Employers will be billed directly on a quarterly basis on the mutually agreed upon
date disclosed in the engagement agreement between the 401k Employer and alooola, LLC.

         alooola, LLC                                                    Form ADV Part 2A

Item 7 – Types of Clients

alooola, LLC provides investment management services to Individuals, 529 Account Holders, 401k
plan sponsors, trusts, estates, charitable organizations. alooola, LLC does not impose a minimum
account size requirement.