Claro Advisors Inc

Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client
engaging the Advisor for services described herein shall be required to enter into one or more agreements with the Advisor.

A. Fees for Advisory Services
Investment Management Services
Claro charges an annual investment advisory fee ranging from 0.50% to 1.50% of assets under management, depending on the
scope of services, complexity of the relationship, level of assets to be managed, portfolio restrictions, reporting requirements, and
overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions,
and other complexities may be charged a higher fee within this range.
Investment advisory fees are typically paid quarterly, in advance of each calendar quarter, pursuant to the terms of the Client
agreement. Investment advisory fees are generally based on the market value of assets under management at the end of the prior
calendar quarter. Investment advisory fees for individual and/or self-directed 401(k) and 403(b) accounts are paid quarterly in
arrears and are based on the market value of assets under management at the end of each calendar quarter. Certain legacy Clients
may not be subject to the billing methodology stated above.

CLARO ADVISORS INC. · FORM ADV PART 2A & PRIVACY POLICY                                                                              8

CLARO ADVISORS INC.                                                                             FORM ADV PART 2A & PRIVACY POLICY

The investment advisory fees are prorated from the inception date of the account[s] to the end of the first quarter. Fees are
negotiable at the sole discretion of the Advisor. The Client's fees will take into consideration the aggregate assets under
management with the Advisor. All securities held in accounts managed by Claro will be independently valued by the Custodian.
Claro will conduct periodic reviews of the Custodian's valuations to ensure accurate billing.
The Advisor's fee is exclusive of, and in addition to, any applicable securities transaction fees, custody fees, Portfolio Boost™ fees,
Claro Intelligent Strategies™ fees, Independent Manager fees, and other related costs and expenses described in Item 5.C below,
which may be incurred by the Client.

Portfolio Boost™ Fee
Portfolio Boost™ is a service offered for an additional fee, either as part of the Claro Growth Program™ service model or through
separate enrollment by the Client's advisor. The Portfolio Boost™ fee is:
   Up to 0.06% annually
   Billed monthly in arrears
   Applied across assets supported by the service, as defined in the Client agreement, at the end of each month.
Portfolio Boost™ fees are separate from, and in addition to, the Client's investment advisory fee and any applicable Claro
Intelligent Strategies™ fees and may be waived at the sole discretion of the Advisor.

Claro Intelligent Strategies™ Fees
Client assets that are placed and managed under the Claro Intelligent Strategies™ are charged fees in addition to the investment
advisory fees disclosed above. The Claro Intelligent Strategies™ fee is:
   Up to 0.12% annually
   Billed monthly in arrears
   Based on the assets invested in Claro Intelligent Strategies™ at the end of each month.
These fees are separate from, and in addition to, the Client's investment advisory fee and any applicable Portfolio Boost™ fee.
These fees may be waived at the sole discretion of the Advisor.

Claro Growth Program™ Fee Structure
Clients participating in the Claro Growth Program™ are subject to a bundled service model that includes Portfolio Boost™ as a
core component. For CGP Clients:
   The Portfolio Boost™ fee of up to 0.06% annually applies to CGP Client assets
   Additional fees of up to 0.12% annually apply only to assets invested in Claro Intelligent Strategies™
   Strategy fees are separate from and in addition to the Portfolio Boost™ fee
   Such fees are billed monthly in arrears
The CGP is designed as a streamlined, bundled service model and may be offered at a lower overall fee structure than certain
customized or legacy advisory relationships. The total combined fees for Investment Advisory Services, Portfolio Boost™, and
Claro Intelligent Strategies™ within CGP will not exceed 0.93% (93 basis points) annually for assets serviced under CGP, pursuant
to the terms of the Client agreement.

CLARO ADVISORS INC. · FORM ADV PART 2A & PRIVACY POLICY                                                                              9

CLARO ADVISORS INC.                                                                           FORM ADV PART 2A & PRIVACY POLICY

Use of Independent Managers
As noted in Item 4, the Advisor may implement a portion of a Client's investment portfolio utilizing one or more Independent
Managers. The Client's overall fees may include Claro's investment advisory fee plus investment management fees and/or
platform fees charged by the Independent Manager[s], as applicable. In certain cases, the Advisor and the Independent Manager
will collect fees separately. The total blended fee, including the Advisor's fee and the Independent Manager's fee, will not exceed
3.00% annually.

Financial Planning and Consulting Services
Claro offers financial planning or consulting services on an hourly basis at a rate of up to $300 per hour or on a fixed fee basis,
which may be negotiable depending on the nature and complexity of each Client's circumstances. An estimate for total hours
and/or costs will be determined prior to establishing the advisory relationship. For these engagements, the Advisor shall complete
all services within six (6) months.
Claro may also offer financial planning and consulting services based on an annual retainer of up to $6,500 a year. Retainer fees
...

Types of Clients
Claro offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and retirement
plans. These amounts may change over time and are updated at least annually by the Advisor. The amount of each type of Client is
available on Claro's Form ADV Part 1A. These amounts will change over time. Claro generally does not impose a minimum account
size for establishing a relationship.