Comima LLC

Item 5: Fees and Compensation

A. Fee Schedule

Portfolio Management Fees

        Total Assets Under Management             Annual Fees
        $1 - $1,000,000                           0.90%

        $1,000,001 - $2,000,000                   0.85%

        $2,000,001 - $4,000,000                   0.80%

        $4,000,001 - $6,000,000                   0.75%

        $6,000,001 - $8,000,000                   0.70%

        $8,000,001 - AND UP                       0.65%

       NSWM uses an average of the daily balance in the client's account throughout the billing
       period, after taking into account deposits and withdrawals, for purposes of determining
       the market value of the assets upon which the advisory fee is based.

       These fees are generally negotiable and the final fee schedule will be memorialized in the
       client’s advisory agreement. Clients may terminate the agreement without penalty for a
       full refund of NSWM's fees within five business days of signing the Investment Advisory
       Contract. Thereafter, clients may terminate the Investment Advisory Contract
       immediately upon written notice.

       B. Payment of Fees

       Payment of Portfolio Management Fees

       With the client's written authorization, asset-based portfolio management fees are
       withdrawn directly from the client's account every quarter. Fees are paid in arrears.

       C. Client Responsibility For Third Party Fees

       Clients are responsible for the payment of all third-party fees (i.e. custodian fees,
       brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
       distinct from the fees and expenses charged by NSWM. Please see Item 12 of this brochure
       regarding broker-dealer/custodian.

       D. Prepayment of Fees

       NSWM collects its fees in arrears. It does not collect fees in advance.

       E. Outside Compensation For the Sale of Securities to Clients

       Neither NSWM nor its supervised persons accept any compensation for the sale of
       investment products, including asset-based sales charges or service fees from the sale of
       mutual funds.

Item 7: Types of Clients

NSWM generally provides advisory services to the following types of clients:

       ❖      Individuals
       ❖      High-Net-Worth Individuals
       ❖      Corporations or Business Entities

There is no account minimum for any of NSWM’s services.