Dragus Capital LLC

Item 5. Fees and Compensation

         Dragus provides investment management services (discretionary and non-discretionary) for an annual
         fee. Dragus’ annual fee is exclusive of, and in addition to brokerage commissions, transaction fees and
         other related costs and expenses which are incurred by the client. Dragus does not, however, receive
         any portion of these commissions, fees and costs. The annual fee is charged quarterly, in arrears, and is
         based upon the market value of the assets being managed by Dragus. The market value is the value of
         the assets on the last day of the previous quarter as valued by the Custodian. The annual fee ranges up
         to 1.5% of the market value of the assets under management. For accounts with a margin balance, you
         are assessed on the management fee based on the gross value of the assets in your account. In other
         words, the account value on which the fee is calculated is not reduced by the margin balance..

         Dragus, in its sole discretion, may negotiate to charge a fixed fee or lesser management fee based upon
         certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar
         amount of assets to be managed, related accounts, account composition, pre-existing client relationships,
         account retention, pro bono activities, etc. Therefore, clients with similar assets under management and
         investment objectives may pay significantly higher or lower fees than other clients.

         Wealth Planning Services Fees

         As described in Item 4 above, Dragus provides Wealth Planning Services to certain clients. The fees
         charged for these services are negotiable, based upon the complexity of the services provided.

         For establishing an entity structure (e.g., a Trust and/or offshore company), Dragus charges its clients a
         fixed fee up to $5,000. After establishment of the entity structure, Dragus charges a fixed fee up to $3,000
         for annual maintenance of the entity. With respect to the Trusts, the wealth planning services fees are in
         addition to the fees charged by the Trustee for administration services. When the Trustee invoices the
         client for administration of the Trust, the invoice includes Dragus’ wealth planning services fee. The
         Trustee forwards this fee to Dragus upon receipt of payment from the client. With respect to offshore
         companies, Dragus invoices its wealth planning services fees directly to the clients. Expenses incurred
         by the registered agent of the company for maintenance of the entity structure are reimbursed by Dragus
         upon receipt of payment from the client.

         Any additional services that are not associated with establishing or maintaining the entity structure will
         be billed at the hourly rate of $250 per hour.

         Consulting Services Fees

         The fees charged by Dragus for consulting services are charged at a rate of $250 per hour. Incidental
         expenses associated with providing these services (e.g., travel, transportation, hotels, and meals) are in
         addition to the hourly fee.

     Disclosure Brochure

         Fees Charged by Financial Institutions and Trust Providers

         As further discussed in response to Item 12 below, Dragus recommends the services of several financial
         institutions with which it has negotiated discounted transaction fees for investment accounts. Dragus also
         recommends the services of various trust providers, as discussed in Items 4 and 5 above.

         Clients may incur certain charges imposed by the Financial Institutions and other third parties. The
         charges may include custodial fees, charges imposed directly by a mutual fund or ETF, which are
         disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales
         charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and
         taxes on brokerage accounts and securities transactions. Such charges, fees and commissions are
         charged directly to the client by the broker-dealer and/or custodian and are exclusive of and in addition
         to Dragus’ fee.

         For Wealth Planning Service clients, there are certain fees that are not part of the annual structure
         maintenance fee that are billed to Dragus separately by the provider. Dragus passes these charges along
         to the client in their quarterly invoice as a separate charge.

         Fee Debit

         The Investment Management Agreement entered into between clients and Dragus authorizes Dragus to
         invoice the Financial Institutions directly for the clients’ management fees and to receive payment of the
         fees directly from the Financial Institutions. Clients enter into a separate agreement with the Financial
         Institutions authorizing the Financial Institutions to accept the Dragus’ fee calculations and to remit
         payment directly to Dragus. All Financial Institutions recommended by Dragus have agreed to send
         statements to the clients, or provide online access to the account statements, at least quarterly, indicating
         all amounts disbursed from the account, including the amount of management fees paid directly to
         Dragus.

         Fees for Management During Partial Quarters of Service

         For the initial management period, management fees are calculated on a pro rata basis. Dragus charges
         its initial management fee only for the number of full months in the quarter that assets are designated to
         Dragus for management.

         The Investment Management Agreement between Dragus and the client will continue in effect until
...

Item 7. Types of Clients

          Dragus provides its services to individuals including high net worth individuals, families, companies, and
          institutions. Because of the background of its Principals and their knowledge of the region, Dragus
          specializes in servicing the needs of clients from Latin America, Europe, and North America.

     Disclosure Brochure