Brains Investments LLC

Fees and Compensation

Fees/charges for advisory services are at the rate of $3 per month up to
an account balance of $5,000. Account balances of $5,000 or more are
converted to a fee based upon the account values at end of each month at
an annualized rate of 0.25% and no longer charged the monthly fixed
fee. Advisory fees are charged monthly through our custodian, Apex
Clearing Corporation.

The fees are for advisory services only and do not include any
transaction costs, if any, which may be charged separately by the
custodial firm. The fees are referred to as a “wrap fee” which is a
comprehensive charge levied by an investment advisor to a client for
providing a bundle of services. Such services can include investment
advice, investment research, and brokerage services. Wrap fees allow an
investment advisor to charge one straightforward fee to their clients,
simplifying the process for both the advisor and the customer. Fees are
not negotiable.

Clients authorize the custodian holding client funds and securities to
deduct Brains Investments, LLC advisory fees direct from the client
account in accordance with statements prepared and submitted to the
custodian by Brains Investments, LLC. The custodian will provide
quarterly account statements to the client reflecting all fee withdrawals
by Brains Investments, LLC. It is the client’s responsibility to verify the
accuracy of the fee calculation. The custodian will not determine
whether the fee is properly calculated.

Services will continue until either party terminates the Agreement on 30
business days written notice. If termination occurs prior to the end of a
calendar month, the fees for the month will be calculated on a pro-rata
basis.

The Advisory Agreement contains a pre-dispute arbitration clause.
Client understands that the agreement to arbitrate does not constitute a
waiver of the right to seek a judicial forum where such a waiver would
be void under the federal securities laws. Arbitration is final and
binding on the parties.

Types of Clients and Account Minimums

Brains Investments LLC provides advisory services to individuals
investing in personal, non-retirement portfolios.

The minimum account size is $50, subject to a minimum monthly fee of
$3 per account for account balances under $5,000; or 0.25% on assets
under management for accounts over $5,000, calculated monthly.

Methods of Analysis, Investment Strategies, and Risk of Loss

Brains Investments, LLC uses asset allocation strategies for portfolio
management based on a model of world view, interest, and lifestyle.

By its nature, financial planning looks to the long-term. While there is
risk in all investments, some carry a greater degree of risk or higher
costs. There is no guarantee that the investment strategy selected for the
client will result in the client’s goals being met, nor is there any
guarantee of profit or protection from loss. For those investments sold
by prospectus, clients should read the prospectus in full.

Brains Investments LLC is disclosing those risks and opportunities for
our investment strategy or for particular types of securities used. Debt
securities are subject to interest rate risk.

  ● There are tax consequences for short-term trading wherein capital
    gains are taxed as ordinary income.

  ● Our investment style is a diversified approach, with the goal of
    reducing risks by spreading investments across multiple short-
    medium risk securities. Nonetheless, if the market overall goes
    down due to a recession, depression, or market correction,
    customers’ portfolios will decline in kind as Brains selects equity
    choices across the Russell 3000 list.