Capital Advantage Inc

Item 5 – Fees and Compensation

The specific manner in which fees are charged by Capital Advantage, Inc. is established in a written agreement between each client
and Capital Advantage, Inc. Capital Advantage, Inc. offers investment advisory services for a percentage of assets under
management. All fees are subject to negotiation.

Capital Advantage, Inc. generally bills its fees within one month of the end of each calendar quarter, payable in arrears. Billing
adjustments are made on a prorated basis for all inflows and outflows during the billing period. Unless otherwise arranged, we
directly debit fees from client accounts. Management fees are based on the total value of the client’s accounts, including cash and
accrued interest, and are prorated for each capital contribution and withdrawal made during the applicable calendar quarter.
Accounts initiated during a calendar quarter will be charged a prorated fee, and for accounts that are terminated, the fee will be
prorated to the date of termination.

Our fees for investment management services are generally assessed in accordance with the following fee schedule:

                   1.00% on the first $2,000,000 Assets under Management;
                   0.90% on the next $2,000,001 - $3,000,000 Assets under Management; 0.85% on the next $3,000,001 -
                   $4,000,000 Assets under Management; 0.75% on the next $4,000,001 - $5,000,000 Assets under Management;
                   0.70% on the next $5,000,001 - $10,000,000 Assets under Management; 0.50% on the balance over $10,000,000
                   Assets under Management

Fee Dispersion: Capital Advantage, Inc., in its discretion, may charge a lesser investment advisory fee, waive or modify its portfolio
minimum or its minimum annual fee, charge a flat fee, waive its fee entirely, or charge its fee on a different interval, based upon
certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be
managed, related accounts, account composition, complexity of the engagement, anticipated services to be rendered,
grandfathered fee schedules, employees and family members, courtesy accounts, competition, negotiations with client, etc.).

As result of the above, similarly situated clients could pay different fees. In addition, similar advisory services may be available from
other investment advisers for similar or lower fees.

In the event that the client is subject to a minimum quarterly fee, the client could pay a higher percentage fee than referenced
above.

Capital Advantage, Inc. has a minimum account fee for investment management services of $1,125 per quarter. Clients subject to
the minimum account fee could be paying a higher percentage than reflected above. The minimum fee may be waived. Criteria
commonly used to adjust the minimum fee are:

    1.   Date of acquisition
    2.   Additional services requested
    3.   Account investment objective
    4.   Prospective additional business
    5.   Amount of assets under management
    6.   Legacy fee arrangements

Capital Advantage, Inc.’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses,
which clients remain responsible for paying. Clients may also incur certain charges imposed by custodians, brokers, third party
investment advisers and other third parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire
transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. These fees and
expenses are in addition to Capital Advantage, Inc.’s fee. Capital Advantage, Inc. and its supervised persons do not receive any
portion of these fees and expenses. Nor does it receive compensation from the sale of any securities or investment products.
Clients engaging Independent Manager(s) will incur additional investment advisory fees.

Capital Advantage, Inc. implements the client’s investment strategy by investing in various types of securities, including mutual
funds and exchange traded funds. Mutual funds and exchange-traded fund investors incur additional fees and expenses that are
borne by each shareholder (i.e., management fees) and are disclosed in each fund’s prospectus. Clients could invest in a mutual
fund or exchange-traded fund directly, without the services of Capital Advantage, Inc. In that case, clients would not receive the
services provided by Capital Advantage, Inc., which are designed, among other things, to assist the client in determining which
securities are most appropriate for their individual financial situation and investment strategy.

Capital Advantage, Inc. has set its rates to take into consideration these additional charges - if any. However, Capital Advantage,
Inc. recommends that clients review the fees charged by the funds, custodians and broker dealers and the fees charged by Capital
Advantage, Inc. to fully understand the total amount of fees to be paid by the client and to evaluate the advisory services being

provided.

Item 12, “Brokerage Practices” further describes the factors that Capital Advantage, Inc. considers in selecting or recommending
broker-dealers for client transactions and determining the reasonableness of their compensation (i.e., commissions).

Item 7 – Types of Clients
Capital Advantage, Inc. offers its advisory services to individuals, high net worth individuals, trustees, pension and profit- sharing
plans, charitable organizations and corporations or other business entities.

Participation in advisory services requires a minimum portfolio size of $500,000. The minimum portfolio size of $500,000 may be
waived for our clients based on individual client circumstances. Additionally, certain related accounts may be aggregated for the
purpose of achieving the minimum account size.