Croak Asset Management LLC

Fees and Compensation - Item 5

 Portfolio Management Services
 Our fee for portfolio management services is based on a percentage of the assets in your account and is set forth
 in the following annual blended fee schedule:

Croak Asset Management
Form ADV Part 2A

          Assets Under Management                     Annual Fee Schedule
          First $100,000                              1.35%
          Next $150,000                               1.25%
          Next $250,000                               1.15%
          Next $500,000                               1.05%
          Over $1,000,000                             0.95%

 The annual fee for the first partial quarter will be prorated and paid at the end of the quarter. Subsequently, the
 fee will be paid quarterly in advance based upon the balance at end of previous quarter. The fee will be adjusted
 for all inflows and outflows throughout the billing period. Our advisory fee is negotiable, depending on individual
 client circumstances. The exact fee payable by the client along with the payment method will be clearly listed in
 the advisory agreement.

 At our discretion, we may combine the account values of family members living in the same household to
 determine the applicable advisory fee. For example, we may combine account values for you and your minor
 children, joint accounts with your spouse, and other types of related accounts. Combining account values may
 increase the asset total, which may result in your paying a reduced advisory fee based on the available breakpoints
 in our fee schedule stated above.

 We will deduct our fee directly from your account through the qualified custodian holding your funds and
 securities. We will deduct our advisory fee only when the following requirements are met:

     •    You provide our firm with written authorization permitting the fees to be paid directly from your account
          held by the qualified custodian.
     •    The qualified custodian agrees to send you a statement, at least quarterly, indicating all amounts
          disbursed from your account including the amount of the advisory fee paid directly to our firm.

 We encourage you to reconcile our fees with the statement(s) you receive from the qualified custodian. If you
 have any questions about the statement(s), if you find any inconsistent information between our fees and the
 statement(s) you receive from the qualified custodian, or, if you did not receive a statement when expected, call
 our main office number located on the cover page of this brochure.

 Held Away Account Services - Billing
 We charge an annual fee for services provided to these held away accounts, which is deducted from an account
 under our Investment Management Service on a quarterly basis in advance or at our discretion, we will invoice
 you for direct payment due upon receipt of the quarterly invoice. Fees are based on the assets within these
 accounts, and are charged at the standard fee schedule according to the valuation of the accounts at the close of
 the quarter as valued by the account custodian. All fees, payment options, and terms will be set forth clearly in
 the advisory agreement.

 You may terminate the portfolio management agreement or advisory agreement upon 30 days written notice.
 You will incur a pro rata charge for services rendered prior to the termination of the portfolio management
 agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for
 which you are a client. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated
 refund of those fees.

 Selection of Other Advisers Fees
 We may direct clients to third-party investment advisers. We will be compensated via a fee share from the
 advisers to which we direct those clients. The fees shared are negotiable and will not exceed any limit imposed
 by any regulatory agency. The notice of termination requirement and payment of fees for third-party investment
 advisers will depend on the specific third-party adviser selected.

Croak Asset Management
Form ADV Part 2A

 Morningstar Investment Services, LLC
 Where we direct clients to Morningstar Investment Services, LLC, the annual fee schedule will be as follows:

                    Total Assets             Croak Asset             Morningstar’s Fee            Total Fee
                                           Management’s Fee
                      All Assets                    1.35%                    0.55%                  1.90%

 Fees for selection of Morningstar Investment Services, LLC as third-party adviser are withdrawn by Morningstar
 Investment Services, LLC directly from client accounts. We then receive our portion of the fees from Morningstar
 Investment Services, LLC.; we do not directly deduct the advisory fees. Fees are paid quarterly in advance.

 AssetMark Investment Services Inc.
 Where we direct clients to AssetMark Investment Services Inc., the annual fee schedule will be as follows:

                    Total Assets              Croak Asset        AssetMark’s Fee                     Total Fee
                                          Management’s Fee
                  Up to $1 million        1.35%            0.45%                                  1.80%
               $1 million to $3 million   1.35%            0.35%                                  1.70%
                  Over $3 million         1.35%            0.30%                                  1.65%

 Fees for selection of AssetMark Investment Services Inc. as third-party adviser are withdrawn by AssetMark
 Investment Services Inc. directly from client accounts. We then receive our portion of the fees from AssetMark
 Investment Services Inc.; we do not directly deduct the advisory fees. Fees are paid quarterly in advance.

 Financial Planning and Consulting Services Fees
...

Types of Clients - Item 7

 We offer investment advisory services to individuals (other than high-net-worth individuals), high net worth
 individuals, pension and profit-sharing plans (but not the plan participants), charitable organizations, and
 corporations or other businesses not listed above.

 In general, we do not require a minimum dollar amount to open and maintain an advisory account; however, we
 have the right to terminate your account if it falls below a minimum size that, in our sole opinion, is too small to
 manage effectively.

                       Methods of Analysis, Investment Strategies and Risk of Loss - Item 8

 Croak Asset Management advisors may use various methods to determine an appropriate investment strategy
 for your portfolio with the goal of reducing risk and increasing performance in each customized portfolio. We
 seek to recommend investment strategies or products that will give you a diversified portfolio consistent with
 your investment objective. We do this by analyzing the various products, investment strategies, and money
 management firms to which we provide access. That analysis includes a review of the structure, cost, and
 investment performance history of each program.