American Capital Advisory LLC

Item 5 – Fees and Compensation

American Capital Advisory, LLC (ACA) charges fees based on a percentage of assets under
management. ACA's fees are calculated based on the total market value of the account at the end
of each month, and payable in arrears at an annual rate based on the following schedule, unless
otherwise negotiated:

                                      0-$1MM - 1.00%
                                      $1-2MM - 0.90%
                                      $2-3MM - 0.80%
                                      $3-4MM - 0.70%
                                      $4-5MM - 0.60%
                                   $5MM and above - 0.50%

Lower fees for comparable services may be available from other sources.

For those clients who use margin accounts, ACA's fees are calculated based on the net asset
value of the account at the end of the month, and payable in arrears at an annual rate based on the
above schedule. In some cases, clients are able to request a reduced fee based on the total value
of securities managed not including the margin balance.

Some clients have decided to use their margin capability as a method to fund outside
investments, in which case they have withdrawn sums of money out of their accounts because of
favorable margin interest rates. For those clients who choose to margin accounts, the fee charged
by ACA is based on the debit amount added back to the portfolio. In some cases, clients may
request a reduced fee based on the total value of securities managed not including the margin
balance.

An example of this would be if Client A's portfolio value is $5,000,000 and they decide to
withdraw $1,500,000 on margin to fund another investment opportunity. When calculating the
monthly fee, ACA would add back the $1,500,000 to the net asset value of Client A's account to
determine the appropriate fee. In this example, the client would be charged a fee on $5,000,000;
$3,500,000 net asset value plus the $1,500,000 margin withdrawal.

ACA deducts fees monthly from clients' accounts.

In connection with the advisory services provided by ACA, clients pay other fees including
mutual fund expenses, ETF expenses and custodian fees. Clients will also incur brokerage fees
and transaction costs specific to their custodian. Please see Item 12 – Brokerage Practices.

ACA does not allow clients to pay fees in advance.

Neither ACA nor any supervised person accepts compensation for the sale of securities or other
investment products.

Item 7 – Types of Clients

American Capital Advisory provides investment advisory services to individuals, high net
worth individuals, corporations, trusts, and financial institutions. ACA requires a minimum
of $250,000 for opening or maintaining an account, unless otherwise negotiated. Clients
introduced to the Brave 18 fund must be Accredited Investors. See Item 5—Fees and
Compensation for additional information.