Combinatorics Capital LLC

ITEM 5 – FEES AND COMPENSATION

Item 5.A   Describe how you are compensated for your advisory services. Provide your fee
           schedule. Disclose whether the fees are negotiable.

           As Combinatorics is registered with the SEC and only delivers this brochure to
           "qualified purchasers" as defined under the Investment Company Act of 1940, as
           amended, it has opted not to include a fee schedule herein.

           It is critical that the Managed Account clients refer to the relevant advisory
           agreement and other governing documents for a complete understanding of
           how Combinatorics is compensated for its advisory services.
Item 5.B   Describe whether you deduct fees from clients’ assets or bill clients for fees
           incurred. If clients may select either method, disclose this fact. Explain how often
           you bill clients or deduct your fees.

           Combinatorics generally bills the Managed Accounts for fees incurred. The
           Managed Accounts do have the ability to choose to be billed directly for fees
           incurred. The Managed Accounts are each subject to different fee arrangements as
           such arrangements are individually negotiated.

           It is critical that the Managed Account clients refer to the relevant advisory
           agreement and other governing documents for a complete understanding of
           how fees are deducted from their assets. The information contained herein is
           a summary only and is qualified in its entirety by such documents.
Item 5.C   Describe any other types of fees or expenses clients may pay in connection with
           your advisory services, such as custodian fees or mutual fund expenses. Disclose
           that clients will incur brokerage and other transaction costs, and direct clients to
           the section(s) of your brochure that discuss brokerage.

           The Managed Accounts are each subject to different terms with respect to the
           payment of fees and expenses as such fee and expenses arrangements and terms
           are individually negotiated. In addition, the Managed Accounts will incur
           brokerage and other transaction costs. Please refer to item 12 of this brochure for
           a discussion of Combinatorics’ brokerage practices.

           It is critical that the Managed Account clients refer to the relevant advisory
           agreement and other governing documents for a complete understanding of
           expenses. The information contained herein is a summary only and is
           qualified in its entirety by such documents.
Item 5.D   If your clients either may or must pay your fees in advance, disclose this fact.
           Explain how a client may obtain a refund of a pre-paid fee if the advisory contract
           is terminated before the end of the billing period. Explain how you will determine
           the amount of the refund.

           Generally, Combinatorics does not bill the Managed Accounts in advance.

           It is critical that the Managed Account clients refer to the relevant advisory
           agreement and other governing documents for a complete understanding of
           expenses and when fees are charged. The information contained herein is a
           summary only and is qualified in its entirety by such documents.

Item 5.E     If you or any of your supervised persons accepts compensation for the sale of
             securities or other investment products, including asset-based sales charges or
             service fees from the sale of mutual funds, disclose this fact and respond to
             Items 5.E.1, 5.E.2, 5.E.3 and 5.E.4.

             Not applicable.
Item 5.E.1   Explain that this practice presents a conflict of interest and gives you or your
             supervised persons an incentive to recommend investment products based on the
             compensation received, rather than on a client’s needs. Describe generally how
             you address conflicts that arise, including your procedures for disclosing the
             conflicts to clients. If you primarily recommend mutual funds, disclose whether
             you will recommend “no-load” funds.

             Not applicable.
Item 5.E.2   Explain that clients have the option to purchase investment products that you
             recommend through other brokers or agents that are not affiliated with you.

             Not applicable.
Item 5.E.3   If more than 50% of your revenue from advisory clients results from commissions
             and other compensation for the sale of investment products you recommend to
             your clients, including asset-based distribution fees from the sale of mutual funds,
             disclose that commissions provide your primary or, if applicable, your exclusive
             compensation.

             Not applicable.
Item 5.E.4   If you charge advisory fees in addition to commissions or markups, disclose
             whether you reduce your advisory fees to offset the commissions or markups.

             Not applicable.

ITEM 7 – TYPES OF CLIENTS
Describe the types of clients to whom you generally provide investment advice, such as individuals,
trusts, investment companies, or pension plans. If you have any requirements for opening or maintaining
an account, such as a minimum account size, disclose the requirements.

Combinatorics currently provides investment advisory services to separately managed accounts of
financial institutions. Managed account relationships are generally subject to significant account
minimums and the fee arrangements and other terms are individually negotiated.