freeGulliver LLC

Item 5 Fees and Compensation
Portfolio Management Services
Our fee for portfolio management services is most commonly based on a percentage of the assets in
your account and is set forth in the following annual fee schedule:

Annual Fee Schedule

   Assets Under Management                                                   Annual Fee
            Below $1,000,000                                                 1.00%
            $1,000,001 - $5,000,000                                          0.75%
            $5,000,001 - $25,000,000                                         0.50%
            Above $25,000,000                                                0.30%
            Tracked Assets Only*                                             0.10%

      *Tracked assets fee is not in addition to AUM fees

The above represents the Firm's standard blended fee schedule and may be subject to change. Actual
fees may vary based on client circumstances and are set forth in the client agreement.

Our annual portfolio management fee is payable quarterly in advance, and deducted from the client's
account, or in accordance with their instructions. Fees are based on the average daily balance of the
account during the prior calendar quarter (unless otherwise specified in the client agreement). Fees
apply to assets under management and generally exclude private investments managed by FreeGulliver
or its affiliates, unless otherwise agreed in writing with the client.

If the portfolio management services are agreed to at any time other than the first day of a calendar
quarter, our fees will apply on a pro rata basis from the date of the first deposit, which means that the
advisory fee is payable in proportion to the number of days in the quarter for which you are a client.

The fee for portfolio management services may also be an annual flat fee, payable quarterly in advance.
Our advisory fee is negotiable, depending on individual client circumstances. Fee schedules, billing
methods, and breakpoints may differ for certain clients based on legacy arrangements or negotiated
terms.

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 send you an invoice for the payment of our advisory fee, or 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 you have given our firm written authorization permitting the fees to be paid directly
from your account. Further, the qualified custodian will deliver an account statement to you at least
quarterly. These account statements will show all disbursements from your account. You should review
all statements for accuracy. We encourage you to check the fees deducted on the statements you receive
from the qualified custodian. If you find any inconsistent information or have questions, call our main
office number located on the cover page of this brochure.

You may be billed directly by us for our service fees. If so chosen, you will be invoiced by the fifth
business day of the month subsequent to the most recently ended billing period. Payments are due on
or by the final business day of the month in which the invoice is generated.

You may terminate the portfolio management services upon written notice. You will incur a pro rata
charge for services rendered prior to the termination of your portfolio management services, 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.

Legacy clients may pay a flat fee or have a different fee schedule and billing practice. Such arrangements
may differ from the fee schedule described above and are documented in the applicable client
agreement.

Financial Planning and Financial Consulting Services
We charge a fixed fee for financial planning and financial consulting services. Our fixed fee generally

ranges between $1,000 to $25,000. The first half of the estimated fee is due in advance of services
rendered with the remaining balance payable upon completion of the agreed upon services. The fee is
negotiable depending upon the complexity and scope of the plan, your financial situation, and your
objectives. Should the engagement last longer than six months between acceptance of financial planning
services and delivery of the financial plan, any prepaid unearned fees will be promptly returned to you
less a pro rata charge for bona fide financial planning services rendered to date. At our discretion, we
may offset our financial planning fees to the extent you implement the financial plan through our portfolio
management service.

You may terminate the financial planning and consulting services upon written notice to our firm. If you
have pre-paid financial planning fees that we have not yet earned, you will receive a prorated refund of
those fees. If financial planning fees are payable in arrears, you will be responsible for a prorated fee
based on services performed prior to termination of the financial planning and consulting services

Selection of Other Advisers
Advisory fees charged by TPMMs are separate and apart from our advisory fees. Assets managed by
TPMMs may be included in calculating our advisory fee depending on the client arrangement. This
practice results in clients paying advisory fees to both the TPMM and FreeGulliver, which creates an
incentive for FreeGulliver to recommend TPMMs. Advisory fees that you pay to the TPMM are
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Item 7 Types of Clients
We offer investment advisory services to individuals, including high net worth individuals, private
pooled investment vehicles, pension and profit sharing plans, charitable organizations, corporations and
other business entities.

Portfolio management clients with assets under our management that are less than $1,000,000, we
charge a 1% flat fee.
Pension consulting clients with assets under our management that are less than $300,000, may be
charged an additional fee. The additional fee will typically be $1,500 per year.

Certain legacy clients will have different fee schedules than what is disclosed in this Brochure.

We may also combine account values for you and your minor children, joint accounts with your spouse,
and other types of related accounts to meet the stated minimum.