Circle Advisers Inc

Item 5           Fees and Compensation

   A. The client can determine to engage the Registrant to provide non-discretionary investment
      advisory services on a fee basis.

         INVESTMENT ADVISORY SERVICES
         If a client determines to engage the Registrant to provide non-discretionary investment
         advisory services on a fee basis, the Registrant’s annual investment advisory fee shall be
         based upon a percentage (%) of the market value and type of assets, including cash and
         cash equivalents, placed under the Registrant’s management, generally on a stepped-up
         basis as follows:

                    Market Value of Portfolio Assets         % of Assets
                    First $1,000,000                         1.00%
                    From $1,000,001 to $2,000,000            0.80%
                    From $2,000,001 to $5,000,000            0.60%
                    Above $5,000,000                         0.40%

         On a case by case basis and in our sole discretion, our fees may be negotiable, based on
         the specific circumstancesof a given client.

         Please Note: Our fee schedule may present a conflict of interest to the extent that it
         incentivizes us to allocate less of your investment assets to cash or fixed income holdings
         to increase our compensation.

         FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
         To the extent specifically requested by a client, the Registrant may determine to provide
         financial planning and/or consulting services (including investment and non-investment
         related matters, including estate planning, insurance planning, etc.) on a stand-alone fee
         basis. Registrant’s planning and consulting fees are negotiable, but generally range from
         $2,500 to $6,000 on a fixed fee basis, and from $125 to $500 on an hourly rate basis,
         depending upon the level and scope of the service(s) required and the professional(s)
         rendering the service(s).

         Fee Dispersion. Registrant, in its discretion, may charge a lesser investment advisory fee,
         charge a flat fee, waive its fee entirely, or charge 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.). Please Note: 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. ANY QUESTIONS: Registrant’s Chief Compliance Officer, Eric
    Block, remains available to address any questions that a client or prospective client may
    have regarding advisory fees.

B. Clients may elect to have the Registrant’s advisory fees deducted from their custodial
   account. Both Registrant's Investment Advisory Agreement and the custodial/ clearing
   agreement may authorize the custodian to debit the account for the amount of the
   Registrant's investment advisory fee and to directly remit that management fee to the
   Registrant in compliance with regulatory procedures. In the limited event that the Registrant
   bills the client directly, payment is due upon receipt of the Registrant’s invoice. The
   Registrant shall deduct fees and/or bill clients quarterly in advance, based upon the market
   value of the assets on the last business day of the previous quarter.

C. As discussed below, when requested to recommend a broker-dealer/custodian for client
   accounts, Registrant generally recommends that Schwab or Fidelity serve as the broker-
   dealer/custodian for client investment management assets. Broker-dealers such as Schwab
   and Fidelity charge brokerage commissions, transaction, and/or other type fees for effecting
   certain types of securities transactions (i.e., including transaction fees for certain mutual
   funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The
   types of securities for which transaction fees, commissions, and/or other type fees (as well
   as the amount of those fees) shall differ depending upon the broker-dealer/custodian. While
   certain custodians, including Schwab and Fidelity, generally (with the potential exception
   for large orders) do not currently charge fees on individual equity transactions (including
   ETFs), others do. Please Note: there can be no assurance that Schwab and/or Fidelity will
   not change their transaction fee pricing in the future. Please Also Note: Fidelity and Schwab
   may also assess fees to clients who elect to receive trade confirmations and account
   statements by regular mail rather than electronically. Tradeaways: When beneficial to the
   client, individual fixed‐income and/or equity transactions may be effected through broker‐
   dealers with whom Registrant and/or the client have entered into arrangements for prime
   brokerage clearing services, including effecting certain client transactions through other
   SEC registered and FINRA member broker‐dealers (in which event, the client generally will
   incur both the transaction fee charged by the executing broker‐dealer and a “trade-away”
   fee charged by Schwab and/or Fidelity). The above fees/charges are in addition to
   Registrant’s investment advisory fee at Item 5 below. Registrant does not receive any
   portion of these fees/charges. ANY QUESTIONS: Registrant’s Chief Compliance
   Officer, Eric Block, remains available to address any questions that a client or
   prospective client may have regarding the above.

D. Registrant's annual investment advisory fee shall be prorated and paid quarterly, in
...

Item 7           Types of Clients

         The Registrant’s clients shall generally include individuals and pension and profit sharing
         plans. The Registrant generally requires an annual minimum fee of $2,500. The Registrant,
         in its sole discretion, may charge a lesser investment advisory fee charge a flat fee, waive
         its fee entirely, or charge 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.). Please
         Note: 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 the annual minimum fee, the client could
         pay a higher percentage fee than referenced above.