Bridgefront Capital LLC

Item 5 - Fees and Compensation

A. Below is a discussion of how the Adviser is compensated in connection with
    providing advisory services to the Managed Accounts, respectively.

    Managed Accounts

        With respect to the Managed Accounts, the fees vary from Client to Client and are
        negotiated with each particular Client. Generally, the Managed Accounts are subject
        to management fees and performance-based fees. Management fees can be
        structured as a fixed fee or as a percentage of overall account value. Performance
        fees are typically a percentage of the overall performance of the accounts during a
        given period of time.

B. Management Fees and Performance Allocations from the Clients are deducted directly
    from the Client’s capital, where Management fees are payable quarterly in advance,
    and Performance Allocations are paid at the end of each performance period. With
    respect to the Managed Accounts, the Management Fee is payable monthly in advance.
    Such fees are generally paid by the owners of the applicable accounts and not deducted
    from the assets of the Managed Accounts. The Adviser is compensated for the
    Performance Allocations pursuant to advisory agreements that are negotiated with each
    Managed Account.

C. Clients will incur brokerage and other transaction costs. Item 12 of this brochure
    discusses how the Adviser selects brokers and determines the reasonableness of their
    compensation. The direct expenses borne by each Client are described in more detail
    in each Client’s Offering Documents.

D. As stated above, the Managed Accounts pay the Adviser monthly compensation draws
    in advance based on the relevant managed account’s percentage of the Adviser’s assets
    under management. Upon the termination of an advisory contract, a managed account
    shall pay a draw prorated through the end of the foregoing notice period.

E. Other than as described above, neither the Adviser nor any of its supervised persons
    receives any compensation from the sale of securities or other investment products.

F. The Adviser may enter into different fee arrangements on a Client by Client basis and
    will be negotiated with each Client and described in each respective Client's offering
    documents.

Item 7 - Types of Clients

As mentioned in Item 4, the Adviser provides sub-advisory services to private investment
funds for sophisticated, qualified investors. Acceptance of separate account management
relationships is determined on a case-by-case basis.