Fruge' Capital Advisors LLC

Item 5 Fees and Compensation

Description
    FCA bases its fees primarily on a percentage of assets under management for
    investment management as stated above, but FCA may impose hourly charges or
    fixed fees depending on the nature of the client’s needs under separate agreements.
     Financial plans are priced according to the degree of complexity associated with the
     client’s situation. Fees for financial plans or separate consulting may be negotiable.

Fee Billing
    The Investment Management fee shall be prorated and paid quarterly, in advance,
    based upon the market value of the Assets on the last day of the previous quarter as
    valued by the Custodian. Investment management fees are billed quarterly, in
    advance. The client must consent in advance to direct debiting of their investment
    account. Fees are deducted from a designated client account to facilitate billing.
    Additionally, a client will receive statements from the Custodian evidencing the
    direct debiting of their quarterly investment account for fees. Invoices are available
    illustrating this direct debiting. The quarterly management fee is equal to the annual
    percentage management fee divided by four times the value of the portfolio on the
    last trading day of the relevant quarter. For example, (1.00%/4) x $1,000,000=$2,500
    fee for the quarter. The fee for the initial quarter shall be calculated on a pro rata basis
    commencing on the day the assets are initially designated to us for management
    under the Investment Management Agreement. Multiple client accounts held by
    members of a family household may be aggregated in accordance with the fee
    schedule for household billing purposes. Fees for financial plans are billed upon
    delivery of the financial plan by separate invoice, unless otherwise negotiated. Fees
    for additional services will be billed as required. Fees for such financial plans may be
    debited from investment accounts by consent. If there are fees for any specific project
    or scope of consulting work, the client will be billed upon completion of such work
    and fees are to be paid upon receipt. Any additional fees related to any other scope of
    services may be further negotiated as stated above and client may consent in writing
    to direct debit any investment account for any additional fees.

Other Fees
    Different custodians may charge transaction fees on purchases or sales of certain
    mutual funds and exchange-traded funds. These transaction charges are usually small
    and incidental to the purchase or sale of a security. The selection of the security is
    more important than the nominal fee that the custodian charges to buy or sell the
    security. Charles Schwab is our primary custodian utilized by FCA clients.

     Additional fees may be charged directly to a client for certain third-party platform for
     data reconciliation and reporting, custodial transaction charges and/or separate
     account manager’s expenses or program fees for any third-party asset manager.

Expense Ratios
    Mutual funds and exchange traded funds generally charge a management fee for their
    services as investment managers. The management fee is called an expense ratio.
    For example, an expense ratio of 0.50 means that the mutual fund company charges
    0.5% for their services. These fees are in addition to the fees paid by you to FCA.
     Performance figures quoted by mutual fund companies in various publications are
     after their fees have been deducted.

Past Due Accounts and Termination of Agreement
     FCA reserves the right to stop work on any account that is more than 120 days
     overdue. In addition, FCA reserves the right to terminate any financial planning
     engagement where a client has willfully concealed or has refused to provide pertinent
     information about financial situations when necessary and appropriate, in FCA’s
     judgment, to providing proper financial advice. Any unused portion of fees collected
     in advance will be refunded within 14 days.

Item 7 Types of Clients

Description
    FCA generally provides investment advice to individuals, but may offer advice to
    banks or thrift institutions, investment companies, pension and profit sharing plans,
    trusts, estates, or charitable organizations, corporations or business entities. FCA may
    provide services primarily to individuals and families. We work on a fee-only basis.
    Therefore, we are objective in our analysis and recommendations. By providing
    portfolio investment advice, we take into consideration the client’s goals and
    objectives. Our work allows us to provide a thoughtful asset allocation containing an
    appropriate level of risk needed to meet the client’s goals, but also with an

     understanding that tactical asset allocation can be used at certain times to preserve
     capital.
     We believe that there is no one ordinary client as each client may have different goals
     and objectives based on time horizon, risk tolerance and investments. We strive to
     fully understand our client’s objectives and general risk tolerance, and assist in
     developing strategies to accomplish these goals. With this in mind, many of our
     clients include professionals, executives, business owners, widows and retirees. We
     may also provide investment consulting services for nonprofits, retirement plans and
     corporate assets as well as stand-alone financial planning or other more advanced
     wealth management advisory services as needed. Client relationships vary in scope
     and length of service, and any scope will be included in any agreement between firm
     representatives and the client.

Account Minimums
    FCA does not impose an account minimum for starting or maintaining an account.