Andina Capital Management LLC

FEES & COMPENSATION

Andina’s standard fees for its services are outlined below, as Financial Planning Fees, Investment Management and Additional
Family Office Service Fees, respectively. Notwithstanding, Andina reserves the right to negotiate fee terms when appropriate. Your
Andina Advisory Agreement will reflect the fee terms that are applicable to your engagement with Andina.

When Andina is authorized by the Client, fees are deducted directly from the Client’s custodial accounts. Fees are typically
deducted first from available cash balances or money market funds in the account on which the fees were calculated, or

Form ADV: Part 2A                                   Page 8 of 22                                     Disclosure Brochure

from a specifically designated billing account, upon request. If sufficient cash is not available, a portion of the account’s
assets may be liquidated to satisfy the fee, consistent with the Client’s advisory agreement and custodial procedures. At
the Client’s election, fees may alternatively be invoiced and paid directly rather than deducted from the custodial
account.

FINANCIAL PLANNING

Discovery Meeting

In preparation for a discovery meeting, we will request you bring financial documents for us to review and discuss.

During this meeting we will address your financial concerns and answer your questions about how we can assist you.
We will explain the benefits of financial planning and how a comprehensive evaluation of wealth management
needs is beneficial and recommend possible financial resolutions to improve the likelihood of achieving your goal . We
do not charge a fee for the initial discovery meeting. If, however, you wish no further interaction with us, you will be
responsible for implementing any recommendations coming out of the discovery meeting, in your full discretion.

Financial Planning Fees

For clients selecting our financial planning services, we offer two types of fee schedules described below. Your
agreement with us will contain your specific fee schedule.:

Flat Fee: A one time, flat fee, starting at $500

The Company charges a one-time, flat fee for its planning services, which covers the preparation and delivery of the
Client's financial plan. This fee is non-recurring and will not automatically renew without the Client's prior written
consent. Approximately twelve months after the Planning Services are completed, the Company will evaluate
whether additional planning work is warranted. If so, any additional fee will be documented in writing and agreed to
by the Client before it becomes payable; the Client will never be charged an additional flat fee for planning services
without prior written consent. The Company may, in its sole discretion, waive the planning fee.Specific, Individual
Financial Planning Services: Our fees for individual planning services listed under “Estate, Financial & Tax Planning” will
depend on the services selected. The minimum one-time fee will be $1,000. Fees will be predetermined in consultation
with you and presented in a written proposal or engagement letter.

Termination of Financial Planning Services: You can terminate our agreement, in writing, at any time prior to the
presentation of any final planning documents. We will bill clients paying a flat fee schedule an hourly rate of $500 for
the time spent in the design of such financial documents (minimum 2 hours or $1,000) through the date of termination.
All fees collected in excess of $1,000, or those billed for the time spent if more than $1000, will be returned to you. If you
terminate our Financial Planning Agreement after the financial plan has been delivered to you, we will bill you for
the full fee amount negotiated If you selected financial planning fee that is charged to you in advance, (i.e., a quarterly,
or ongoing asset-based fee schedule) that fee will cease to be charged as of the first day of the quarter following
written notice (January 1, April 1, July 1 or October 1). No fees will be returned.

ADVISORY SERVICES FEES

General: Our fees for investment management services and ongoing financial planning ("Advisory Fees”) are generally
based on a percentage of assets under management. The advisory fee will be calculated in advance, based on the
quarter ending market value of your assets under our management with us (referred to as your “Billable Portfolio”) at a
maximum rate of 2.00% annually. With respect to the value Private Fund assets within your Billable Portfolio, the value of

Form ADV: Part 2A                                     Page 9 of 22                                 Disclosure Brochure

                     such assets under management will be based upon the most recently provided net asset value
from each Private Fund. As a result, Private Fund values may be delayed as compared to the date used to determine
the assets under management associated with other marketable securities in your portfolio. Your specific Advisory Fee
terms will be set forth in our planning and advisory agreement with you.

Flex Account Fees: Flex Accounts within your Billable Portfolio will be charged a reduced investment management fee of
0.20% per annum on cash, cash equivalents, and a certain limited number of ETF assets in any such accounts. Any
other assets in the account(s) will be charged at your “full fee”, as stated in our agreement with you.

Model Management Fees: Participants in a model delivery program will pay a single fee directly to the sponsor. Andina
receives a portion of that fee in exchange for providing the sponsor with the trading signals, which may or may not be
exercised by the sponsor in their discretion. Andina’s fees for providing a model to the sponsor are negotiated on a
program-by program basis and may vary depending on the amount of assets allocated to Andina in the program and
other criteria.

Billing, Deposits and Withdrawals: For investment management accounts opened in during a quarter or for additional
...

TYPES OF CLIENTS

We provide financial planning and investment management services to types of clients that include: individuals and
high net worth individuals, retirement plans, insurance companies and other institutions. We generally require a
minimum initial investment of $50,000 to establish an investment management relationship; however, we retain the
right to waive or reduce this minimum if we feel circumstances are warranted.

METHODS OF ANALYSIS, INVESTMENT STRATEGIES & RISK OF LOSS