Darrow Bentley LLC

Item 5: Fees and Compensation

A. Fee Schedule

Portfolio Management Fees

        Total Assets Under Management          Annual Fees
        All Assets                             Up to 1.00%

The advisory fee is determined based on level of engagement of SRG services which could
include investment selection assistance, financial plan-level consulting and investment
consulting and education requested.

The fee is calculated using the value of the assets in the Account on the last business day
of the prior billing period. For example, the advisory fee is calculated by taking the period
ending account balance and multiplying it by the annualized fee, then divided by the
overall duration of the billing period.

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 SRG's fees within five business days of signing the Investment Advisory
Contract. Thereafter, clients may terminate the Investment Advisory Contract generally
with 30 days' written notice.

Selection of Other Advisers Fees

Clients will pay SRG its standard fee in addition to the standard fee for the advisers to
which it directs those clients. SRG agrees to reduce our standard fee by the amount of the
third party adviser fee. For example, if the agreed upon fee with the client is 1.00% and
the third party money manager’s fee is 0.10%, SRG will reduce the agreed upon fee by
that 0.10% to keep the overall fee at 1.00%. This relationship will be memorialized in each
contract between SRG and each third-party adviser. The fees will not exceed 3% of assets
under management per year.

Pension Consulting Services Fees

Asset-Based Fees for Pension Consulting

        Total Assets Under Management          Annual Fee
        All Assets                             Straight Tier Up to 1.00%

The pension consulting fee is determined based on level of engagement of SRG services
which could include
   • investment selection assistance,
   • plan-level consulting and
   • participant education requested.

SRG uses the value of the account as of the last business day of 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 SRG's fees within
five business days of signing the Investment Advisory Contract. Thereafter, clients may
terminate the pension consulting agreement generally with 30 days' written notice.

For SRG pension consulting services, the client has a choice of paying a fixed rate or hourly
fee, which will be memorialized in the pension consulting agreement.

Fixed Fees

The rate for creating client pension consulting plans is between $200 and $1,000. The fee
is determined based on level of engagement of SRG services which could include
    • investment selection assistance,
    • plan-level consulting and
    • participant education requested.

The final fee schedule will be memorialized in the client’s advisory agreement. This
service may be canceled with 30 days’ notice.

Hourly Fees

The hourly fee for these services is between $100 and $250. The fee is determined based
on level of engagement of SRG services which could include
    • investment selection assistance,
    • plan-level consulting and
    • participant education requested.

The final fee schedule will be memorialized in the client’s advisory agreement.

Financial Planning Fees

For SRG financial planning services, the client has a choice of paying a fixed rate or hourly
fee, which will be memorialized in the pension consulting agreement.

Fixed Fees

The negotiated fixed rate for creating client financial plans is between $250 and $5,000.
The fee is determined based on level of engagement of SRG services which could include
   • investment selection assistance and
   • plan-level consulting

Hourly Fees

The negotiated hourly fee for these services is between $100 and $250. The fee is
determined based on level of engagement of SRG services which could include
   • investment selection assistance and
   • plan-level consulting

Clients may terminate the agreement without penalty, for full refund of SRG’s fees, within
five business days of signing the Financial Planning Agreement. Thereafter, clients may
terminate the Financial Planning Agreement generally upon written notice.

Regarding all SRG portfolio management, pension consulting and financial planning fees,
lower fees for comparable services may be available from other sources.

B. Payment of Fees

Payment of Portfolio Management Fees

Asset-based portfolio management fees are withdrawn directly from the client's accounts
with client's written authorization on a monthly or quarterly basis. Fees are paid in
advance or arrears.

Payment of Pension Consulting Fees

Asset-based pension consulting fees are withdrawn directly from the client's accounts
with client's written authorization or may be invoiced and billed directly to the client.
Clients may select the method in which they are billed. Fees are paid in arrears or
advanced on a monthly or quarterly basis.

Fixed pension consulting fees are paid via check. These fees are paid in arrears upon
completion.

Hourly pension consulting fees are paid 100% in advance, but never more than six months
in advance. For any unearned hourly fees that are collected in advance, the fee refunded
will be the balance of the fees collected in advance minus the hourly rate times the number
of hours of work that has been completed up to and including the day of termination.

For all asset-based fees paid in advance, the fee refunded will be equal to the balance of
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Item 7: Types of Clients

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

       ❖      Individuals
       ❖      High-Net-Worth Individuals
       ❖      Pension and Profit Sharing Plans

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