Elite Income Advisors Inc

Fees and Compensation - Item 5

 Financial Planning Fees
 EIA will charge a fixed fee and/or hourly fee for financial planning services. We utilize the following financial
 planning fee schedules:

         •    Fixed Fees: We charge a fixed fee of up to $10,000.00, for broad-based planning services. In limited
              circumstances, the total cost could potentially exceed $10,000.00. In these cases, we will notify the
              client and may request that the client pay an additional fee.
         •    Hourly Fees: EIA charges an hourly fee of up to $500 for clients who request specific services (such
              as a modular plan or hourly services) and do not desire a broad-based written financial plan.

 Prior to engaging EIA to provide financial planning services, the client will be required to enter into a written
 financial planning Agreement with us. The Agreement will set forth the terms and conditions of the engagement
 and describe the scope of the services to be provided and the portion of the fee that is due from the client.
 Generally, EIA requires a prepayment of 50% of the fee with the remaining balance due upon completion of the
 agreed upon services. EIA does not require the prepayment of over $500, six or more months in advance. Hourly
 fees charged for specific services are payable as invoiced.

Elite Income Advisors, Inc.
Form ADV Part 2A Brochure

 Either party may terminate the financial planning agreement by written notice to the other. In the event the client
 terminates EIA’s financial planning services, the balance of EIA’s unearned fees (if any) shall be refunded to the
 client promptly.

 Portfolio Management Fees
 For portfolio management services, EIA charges an annual fee based on a percentage of assets under
 management. Portfolio management fees are payable monthly in arrears and are based on the average daily value
 of the assets of the month just ended. On an annualized basis, our fees for portfolio management services, subject
 to negotiation, are based on the following blended fee schedule:

                            Assets Under Management                       Annualized Fee
                            $0 to $500,000                                2.00%
                            $500,001 to $1,000,000                        1.90%
                            $1,000,001 to $2,000,000                      1.80%
                            Over $2,000,000                               1.70%

 The fee listed above includes the compensation received by the model provider and the sub-adviser. We may
 modify the fee at any time upon 30 days’ written notice. In certain situations, an added 0.15% may be applied to
 the management fee for certain model providers. This additional fee usually applies to model providers who
 specialize in more aggressive trading strategies. The client will be notified which model providers charge this extra
 management fee at the time of signing the advisory agreement. All accounts will also be assessed a $50 annual
 administrative and technology fee (“ATF”) at the end of the January billing cycle. This $50 fee applies to non-
 managed accounts that are included in our portfolio management systems for accounting and monitoring
 purposes and listed in our performance reports.

 Other fee payment arrangements can be negotiated on a case-by-case basis. These arrangements will be listed in
 the advisory agreement signed by the firm and the client.

 The fee is deducted from the client's account held at the custodian. The sub-adviser calculates the fee and debits
 such fees from the client’s custodial account on behalf of EIA. If insufficient cash is available to pay such fees,
 securities in an amount equal to the balance of unpaid fees will be liquidated to pay for the unpaid balance. In
 limited cases, we may invoice the client directly for the payment of fees.

 Our annual fee is exclusive of and in addition to brokerage commissions, transaction fees, and other related costs
 and expenses, which will be incurred by the client. However, we will not receive any portion of the commissions,
 fees, and costs. Please see Item 12 – Brokerage Practices for further information on brokerage and transaction
 costs.

 The portfolio management agreement may be canceled at any time by the client or by EIA with 30 days’ prior
 written notice to the other party. Refunds are not applicable because the fee is payable in arrears.

 Third Party Manager Fees
 EIA has referral arrangements with a number of TPMs. EIA is compensated via a fee share from the advisors to
 which it directs clients. This relationship is formalized in the contract between EIA and each third-party adviser.
 The fees shared will not exceed any limit imposed by any regulatory agency. Advisory fees that you pay to TPMs
 are established and payable in accordance with the Form ADV Brochure provided by each TPM to whom you are
 referred. These fees may or may not be negotiable.

 You will be required to sign an agreement directly with the TPM(s). You may terminate your advisory relationship
 with the TPM(s) according to the terms of your agreement with the TPM(s). You should review each TPM’s
 brochure for specific information on how you may terminate your advisory relationship and how you may receive

Elite Income Advisors, Inc.
Form ADV Part 2A Brochure

 a refund, if applicable. You should contact the TPM directly for questions regarding your advisory agreement with
 the TPM.

 Since our compensation may differ depending upon our individual agreement with each TPM, we have an
 incentive to recommend one TPM over another third-party adviser with whom we have less favorable
 compensation arrangements or other advisory programs offered by TPM with which we have no compensation
 arrangements. At all times, EIA and its Associated Persons uphold their fiduciary duty of fair dealing with clients.

 Retirement Plan Consulting Fees
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Types of Clients - Item 7

 We generally offer investment advisory services to individuals, pension and profit-sharing plans and their
 participants, trusts, estates, charitable organizations, corporations, and other business entities.

 EIA does not require a minimum amount of assets to establish an advisory relationship. However, some of the
 TPMs recommended by our firm may have their own account minimums.

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

 All asset allocation models are developed by the sub-advisers and/or other third-party model providers (listed
 under Item 4 above) in accordance with investment programs developed by these entities. EIA will not implement
 its own methods of analysis and investment strategies. Clients should refer to the relevant sub-advisers' and/or
 third-party model providers Form ADV Brochures for more information about the methods of analysis and
 investment strategies used by those firms. Security analysis methods used by the recommended sub-advisers
 and/or other third-party model providers may include fundamental analysis, technical analysis, and cyclical
 analysis.

Elite Income Advisors, Inc.
Form ADV Part 2A Brochure

 Investment Strategies
 The investment strategy for a specific client is based upon the objectives stated by the client during consultations
 and documented in the client profile. The client may change these objectives at any time. Each client’s profile
 contains information related to the client’s risk tolerance and any investment restrictions. Any other
 documentation as required by our firm that documents the client’s objectives and their desired investment
 strategy will be retained as part of the client’s file.

 Investing in securities involves risk of loss that clients should be prepared to bear. Clients should fully
 understand the nature of the contractual relationship(s) into which they are entering and the extent of their
 exposure to risk. Certain investing strategies may not be suitable for many members of the public. You should
 carefully consider whether the strategies employed would be appropriate for you in light of your experience,
 objectives, financial resources, and other relevant circumstances.

 Recommendation of Particular Types of Securities: As disclosed under the “Advisory Business” section in this
 Brochure, we provide advice on various types of securities and we do not necessarily recommend one particular
 type of security over another since each client has different needs and different tolerance for risk. Each type of
 security has its own unique set of risks associated with it and it would not be possible to list here all of the specific
 risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in
 very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with
 it.

 General Investment Risk: All investments come with the risk of losing money. Investing involves substantial risks,
 including complete possible loss of principal plus other losses and may not be suitable for many members of the
 public. Investments, unlike savings and checking accounts at a bank, are not insured by the government to protect
 against market losses. Different market instruments carry different types and degrees of risk and you should
 familiarize yourself with the risks involved in the particular market instruments in which you intend to invest.

 Loss of Value: There can be no assurance that a specific investment will achieve its investment objectives and
 past performance should not be seen as a guide to future returns. The value of investments and the income
 derived may fall as well as rise and investors may not recoup the original amount invested. Investments may also
 be affected by any changes in exchange control regulation, tax laws, withholding taxes, international, political and
 economic developments, and governmental economic or monetary policies.

 Interest Rate Risk: Fixed income securities and funds that invest in bonds and other fixed income securities may
 fall in value if interest rates change. Generally, the prices of debt securities rise when interest rates fall, and their
 prices fall when interest rates rise. Longer-term debt securities are usually more sensitive to interest rate changes.

 Credit Risk: Investments in bonds and other fixed income securities are subject to the risk that the issuer(s) may
 not make required interest payments. An issuer suffering an adverse change in its financial condition could lower
 the credit quality of a security, leading to greater price volatility of the security. A lowering of the credit rating of
 a security may also offset the security's liquidity, making it more difficult to sell. Funds investing in lower quality
 debt securities are more susceptible to these problems and their value may be more volatile.

 Foreign Exchange Risk: Foreign investments may be affected favorably or unfavorably by exchange control
 regulations or changes in the exchange rates. Changes in currency exchange rates may influence the share value,
 the dividends or interest earned and the gains and losses realized. Exchange rates between currencies are
 determined by supply and demand in the currency exchange markets, the international balance of payments,
 governmental intervention, speculation, and other economic and political conditions. If the currency in which a
 security is denominated appreciates against the US Dollar, the value of the security will increase. Conversely, a
 decline in the exchange rate of the currency would adversely affect the value of the security.

Elite Income Advisors, Inc.
Form ADV Part 2A Brochure

 Concentrated Position Risk: Certain accounts may, or may be advised to, hold concentrated positions in specific
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