ARAX Advisory Partners LLC

Item 5. Fees and Compensation

AAP primarily receives asset-based advisory fees calculated as a percentage of assets under management or assets under
advisement. AAP also charges fixed or hourly fees for certain financial planning, consulting, and other services, as
described below.

How We Are Compensated

AAP provides investment management services for an annual fee (“management fee”) based on the amount of assets
under AAP’s management. The fee varies depending upon the size of a client’s portfolio and the type of services rendered.
Rates vary depending on the size and complexity of a client’s account and generally range from 0.50% to 3.00% per year
for assets under management and can be lower than the range presented for certain assets under advisement (for
example model portfolio delivery). AAP generally calculates advisory fees based on all assets (including cash and cash
equivalents) held in the account unless otherwise agreed in writing. Employees of the Firm may be charged reduced or
no advisory fees.

Fee Payment Process

All assets in the account are included in the fee assessment unless specifically excluded in writing. Management fees are
generally billed quarterly, either in advance or in arrears, depending on the terms of the client’s Investment Advisory
Agreement. Certain legacy clients are currently billed monthly under their existing agreements. AAP may seek to transition
some or all of these clients to quarterly billing in advance. No change in billing frequency or timing will become effective
unless implemented in accordance with the applicable agreement and any required notice or consent provisions. If a
transition occurs, AAP will prorate or otherwise reconcile fees for the affected period as necessary to avoid charging twice
for the same period and to ensure that any unearned prepaid fee is credited or refunded as required. The methodology
used to calculate fees is described in each client’s agreement and is generally based on either the average daily balance
during the billing period or the ending market value of the account for the quarter. Fees are generally prorated for
accounts opened or terminated during a billing period.

For accounts that are billed in advance, advisory fees for the initial partial quarter are typically billed in arrears on a
prorated basis from the date the account is funded. For accounts held at NFS through USCA Securities and certain accounts
at Schwab and Fidelity, if a client deposits or withdraws assets (cash and/or securities) with a market value of one hundred-
thousand dollars ($100,000) or more in an account on any given day after the inception of a calendar quarter any
additional amount will become subject to additional fees, while any redeemed amount will result in a refund of fees. If
you have any questions about whether this applies to your account, please reach out to your Financial Advisor for more
information. In addition, AAP will make other fee adjustments at the end of any calendar quarter to reflect additions to,
or withdrawals from an account, depending on the terms of the advisory agreement associated with each account Any
such adjustments will be made on a pro rata basis during the calendar quarter for which the adjustment is made.
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Termination of the Advisory Agreement

The Investment Advisory Agreement may be terminated at any time by either party upon written notice.

          •   For accounts billed in advance: Clients will receive a refund of any unearned advisory fees upon termination.
          •   For accounts billed in arrears: Clients remain responsible for payment of any earned but unpaid fees through
              the termination date.

Certain legacy clients may have fee schedules or billing arrangements that differ from those described above.

Use of Margin

Clients may authorize AAP to use margin in the management of their investment portfolio. In such cases, advisory fees are
generally calculated based on the net account value, defined as the total account value minus any margin debt, plus cash
balances, unless otherwise specified in the client’s Investment Advisory Agreement.

Other Types of Fees and Expenses

In addition to the advisory fees paid to AAP, clients will also incur certain charges imposed by other third parties, such as
broker-dealers, qualified custodians, fund managers, trust companies, banks, and other financial institutions (collectively,
“Financial Institutions”). Clients will be charged ticket or transaction charges and other administrative and service fees
based on the activity in their accounts. Such administrative and service fees include account-related fees such as annual
custody fees, mutual fund and ETF expenses, wire fees, IRA maintenance and termination fees, transfer of account fees,
mailgram fees, reorganization fees, service fees, direct registration system (“DRS”) and certificate related fees, legal
transfer and return fees, fees related to ACH, debit, and checking features, stop payment and bounced checks, and trade
extension fees.

Additionally, if external managers are utilized, clients will typically incur additional fees. The method for calculating those
fees, including whether they are paid in advance or arrears, what value they are based on, and how they are paid, will be
disclosed separately in relevant agreements, offering documents or the Form ADV Part 2A of the external manager (if
applicable). As a result, clients may pay multiple layers of fees, including advisory fees charged by AAP as well as fees and
expenses charged by underlying investment products and third-party service providers.

Clients are encouraged to read such disclosure documents, prospectuses, offering documents and agreements carefully
to fully understand the fees and expenses associated with their investments. The Firm’s brokerage practices are described
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Item 7. Types of Clients

The Firm offers investment advisory services to individuals, high net-worth individuals, family offices, trusts, estates,
charitable organizations, business entities, and retirement/profit-sharing plans. AAP generally requires a minimum initial
account size of $50,000 for advisory accounts, although the Firm can waive or reduce this minimum in its sole discretion.

When AAP provides investment advice to clients regarding their retirement plan accounts or individual retirement
accounts, AAP acts as a fiduciary under applicable provisions of the Employee Retirement Income Security Act of 1974
("ERISA") and/or the Internal Revenue Code, as applicable.

AAP also offers portfolio management services to certain pooled investment vehicles and private funds, including legacy
Transcend private funds. Investors in these funds are generally accredited investors, qualified clients, qualified purchasers,
family offices, trusts, estates, corporations, or other entities that meet applicable eligibility requirements. The Funds are
not registered under the Investment Company Act of 1940 in reliance on available exemptions, including Sections 3(c)(1)
and/or 3(c)(7), and interests in the Funds are generally offered pursuant to exemptions from registration under the
Securities Act of 1933, including Regulation D.

The various requirements for investing in a Fund, including the minimum investment size, are set forth in each Fund’s
offering documents. AAP has the ability, in its sole discretion, to permit commitments below the minimum amounts set
forth in the offering documents.

                           Item 8. Method of Analysis, Investment Strategies and Risk of Loss

AAP utilizes a range of methods and analysis to collect and disseminate information, develop tailored investment plans,
identify, evaluate, and select investments strategies and manage a client’s overall assets. In all cases, we are seeking to
exploit investment opportunities and mitigate risk within the investment policy or guidelines specified by each client.
However, investing in securities or investment vehicles of any kind involves the risk of loss that each client should be
prepared to bear.

Investment Strategies

AAP uses various investment strategies in managing clients’ assets. The investment strategy for each client is based upon
the objectives identified during consultations with the client. The client can change these objectives at any time. We
work with each client to understand their financial circumstances, investing experience, investment objectives, risk
tolerance and desired investment strategy and in some cases, we develop or review an Investment Policy Statement
(“IPS”). Portfolios vary from the general asset allocation guidelines at times, provided the portfolios are still designed to
meet the clients’ objectives and investment profile. Investment strategies used by AAP include long-term purchases,
short-term purchases, trading, and margin transactions. Certain strategies involving more active trading will result in
increased brokerage costs, transaction expenses, and taxable short-term gains, which would adversely affect overall
investment performance. AAP also offers advice to clients on investing in alternative investments, where appropriate. In
executing its investment management process, AAP generally utilizes a five-step methodology:

    1.   Analyze Client Time Horizon and Risk Tolerance.
    2.   Determine an Asset Allocation Based on Client Profile.
    3.   Decide on the Investment Process
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    4. Implement the Investment Process through Independent Managers, Mutual Funds, ETFs, Stocks, Bonds, and/or
       Alternative Investments (or other securities); and
    5. Monitor Investments, including review of Independent Managers and Alternative Investments.

We use a number of additional resources when working with clients, designing investment programs and preparing
financial plans. Some of these sources include comprehensive manager performance tracking databases and analytics
tools, macroeconomic portfolio stress testing tools, financially oriented textbooks, marketing materials from product
sponsors, and information provided by an approved third party. Our Associates sometimes also make recommendations
based on specific legal, investment, and tax documents provided by you; however, AAP does not provide tax or legal
advice.

AAP uses computer-based technology to research investments and strategies and to create asset allocation
recommendations. Investments and strategies available are subject to varying degrees of due diligence (quantitative
and/or qualitative) and depth of research. Alternative investments and private placements offered by AAP are subject to
due diligence that often differ in scope and depth from the due diligence conducted for publicly traded securities due to
limitations on available information and transparency.

AAP has access to Fiducient Advisors to provide research on investment managers, asset allocation strategies, financial
market trends and other topical financial issues. They also provide access to proprietary tools such as Frontier Engineer,
which is an asset allocation model, as well as other tools. These are available to assist the Financial Advisor with the
allocation of client assets and the selection of mutual funds, ETFs and other money managers, as well as assist in
rebalancing portfolios.

We, in certain situations, recommend investments in selected private placements, including limited partnerships. These
types of investments often present unique risks due to the use of leverage and potential lack of liquidity. In addition, such
recommendations are often limited only to clients that are “Accredited Investors” and/or “Qualified Purchasers”. These
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