Fogel Capital Management Inc

Item 5 – Fees and Compensation

Pursuant to an advisory contract executed between FCM and a Client, FCM charges an
annual Advisory Fee (the "Advisory Fee"). The Advisory Fee is based on the assets under
management of such Client's account and is charged quarterly in advance; however,
Client accounts may be set up to be charged in advance every month. The Advisory Fee
charged to each Client is generally based on the following schedule and is determined by
the value of the assets in a Client's account, as measured at the end of each calendar
month or quarter, as applicable to each Client account:

       BALANCED PORTFOLIOS                               BOND PORTFOLIOS
       1.25% of the first $3,000,000                     1.25% of the first $3,000,000
       1.00% of the next $2,000,000                      1.00% of the next $2,000,000
       0.75% of the balance                              0.75% of the balance

For certain Clients that require an annual court report filing, FCM will generally charge a
flat fee of $975. This fee will be negotiated with such clients, based on the facts and
circumstances.

The first payment of the Advisory Fee is due upon execution of the Client's Investment
Management Agreement with FCM (the "IMA") and will be assessed on a pro-rata basis.
The Advisory Fee may be negotiable, at the sole discretion of FCM, and will be discussed
prior to FCM initiating the provision of advisory services to such potential clients and, in
all cases, be memorialized in each Client's IMA. Subsequent quarterly payments are due
and will be assessed on the first day of each calendar quarter based on the sum of the
market (net asset) value of the Client's account. This value is calculated as of the close
of business on the last business day of the preceding quarter or month, as applicable.
Should assets be deposited in a Client's account after the inception of a quarter, the
Advisory Fee will be prorated based on the number of days the assets were held in the
account during the quarter or month, as applicable.

For valuation purposes, Client account assets will be treated as if they were held in the
account as of the end of the quarter. Either FCM or the Client will establish a brokerage
account at a designated brokerage firm. The Client shall grant limited trading
authorization to FCM to withdraw the contractually agreed upon Advisory Fee from the
Client's account. FCM will notify the Client in writing of the date of withdrawal, the amount
of withdrawal, and the specific manner and basis on which the Advisory Fee is calculated.
Clients may terminate their respective IMAs with FCM upon thirty days' written notice.

Should a Client's IMA be terminated prior to the end of the quarter, the Advisory Fee will
be returned to the Client on a prorated basis.

Accounts requiring detailed reporting are subject to an additional fee, as negotiated
between the relevant Client and FCM.

FCM provides this Brochure to Clients and prospective clients at least 48 hours prior to
entering into an IMA with a prospective client. In the event the brochure is not delivered
to such Client until execution of the IMA, the Client may terminate the contract without
penalty within five business days after entering into the relevant IMA

General Account Characteristics
All Clients must execute an IMA with FCM. Each IMA contains the terms and disclosure
regarding the services to be provided by FCM, fee structures, risks, and other such
information.

Generally, fees for asset management services are based on a percentage of the market
value of assets under management, including cash. Fees paid to us for investment
advisory services are separate and distinct from the fees and expenses charged by third
parties. The advisory fee does not cover charges imposed by third parties related to
investments held in the account, such as brokerage expenses, including commissions
and transaction charges, contingent deferred sales charges, or 12b-1 trails on mutual
funds. In addition, each mutual fund or third-party money manager charges asset and
management fees, which are in addition to the advisory fees charged by FCM. The fees
charged by such funds or managers are disclosed in each fund's prospectus.

The advisory fee also does not cover debit balances, related margin interest, SEC fees,
or other fees or taxes required by law.

You could invest in a mutual fund directly without our services. In that case, you would
not receive the services provided by us, which are designed, among other things, to assist
in determining which mutual fund or funds are most appropriate for your financial
condition, goals, and objectives. Accordingly, you should review both the fees charged by
the funds and the fees charged by us to fully understand the total fees to be paid and
evaluate the advisory services being provided.

Advisory recommendations are based on your financial situation at the time the services
are provided and are based on financial information disclosed by you. We incorporate
information about trends and performance of securities, the market, and the economy into
our recommendations, which are designed toward meeting your specific goals,
objectives, and needs. Therefore, as your financial information and situation change, you
must notify us promptly.

Item 7 – Types of Clients

We offer investment advisory services to individuals, pension and profit-sharing plans,
charitable organizations, corporations, and non-profit organizations.

Generally, we do not impose a minimum account value required to open and maintain an
advisory account. FCM retains the right to impose such a minimum at our discretion.