Gainvest Legal Corporation

Fees and Compensation
How We Are Compensated

Fees and cash sweep interest are GL’s only compensation, which helps eliminate
conflicts of interest. . GL may retain a percentage of funds received by clients as a
fee. The firm may also receive fees directly from the clients. Lastly, some of the
fund sponsors may pay GL directly.

Cash sweeps are interest generating liquid accounts that use client funds to earn
interest while allowing the client and/or designated operators to deploy capital into
investments.

Wealth Management
Wealth Management clients are billed at the time of service.

GL reserves the right to waive the minimum annual fee, aggregate family accounts
to reach lower fee tiers, or reduce the overall fee under special client circumstances.

How We Collect Our Fees

Our fees are collected at the time of investment of each client’s choosing. Fees

may also be deducted from designated client accounts.
Clients must consent in advance for Silicon Valley Bank to deduct the fees from their
account and the fees will be clearly noted on the client’s statements.
In cases where we provide planning services we will bill the client in lieu of deducting
their fee from an investment account.

Other Fees and Expenses

GL recommends a qualified third-party custodian to hold client accounts, to
ensure an independent accounting and valuation of assets. Clients may select
Silicon Valley Bank to hold their accounts for portfolios that GL manages. As
custodians, Silicon Valley Bank charge transaction fees on purchases and sales of
private funds and stocks, which generally range between $7.95 and $25 per trade,
but may be higher. GL does not receive any portion of these transaction
charges.

Mutual funds charge a management fee for their services as investment managers.
This management fee is called an expense ratio, and is an additional cost to clients.
GL would exclusively recommends low-cost, no-load private funds, and their
fees are not shared with GL.

GL works to minimize the transaction fees on client accounts through reasonable trading;
and mutual management fees by selecting funds that maintain below average annual
expense ratios compared to their peer group funds. The average weighted expense ratio
for a typical GL portfolio ranges between .20% and.35%.

Termination of Services

Clients or GL are permitted to terminate their agreement for services at any time
with written notice. At termination, fees may be pro-rated through the date of
cancellation and charged to the client’s account before assets are transferred away
from GL’s management for the portion of the quarter completed. The portfolio
value as of the date of notification of the termination will be used as the basis for the
fee calculation.

Types of Clients
Description

GL focuses on serving individuals, families, their trusts and estates.
GL feels that it is important for an investment advisor and its clients to have a
good working relationship. To meet this goal, we hold an initial meeting, free of
charge, for any individual interested in using our services. In this meeting we
discuss what they are looking for in an advisor, our investment philosophy, their
financial concerns and goals, and other issues to determine whether we might be a
good fit.

If the potential client wants to proceed, we then prepare an initial set of
recommendations, and further explanation of our financial planning and investment
processes, and present this in a second meeting – also free of charge. Once this
meeting is held, and both the individual and GL are in agreement, they will
become a client.

GL reserves the right to waive the minimum annual fee, aggregate family accounts
to reach lower fee tiers, or reduce the overall fee under special client circumstances.

Methods of Analysis, Investment Strategies and Risk of Loss
Our Investment Philosophy

We believe that investment markets are efficient over the long term. The most
important factors in determining your investment returns are how your assets are
allocated, and how you respond to changes in the market.

Using information gathered from our clients via risk questionnaires, client-provided
financial data, and discussions about goals and concerns; we develop an
investment allocation that is a blend of what they can tolerate emotionally, and what
they need to accomplish financially to meet their goals. We believe in setting
realistic expectations and do not promise the unachievable.

We do not move in-and-out of the market based on predictions of the market’s
future direction, invest in “hot” sectors, or chase the next best private fund or stock

because we do not believe these tactics work. Instead, after determining your
appropriate asset allocation, we implement your investment plan using low cost,
institutional private funds with the goal of capturing as much of the markets’ returns
as possible.

Our Investment Strategy

To implement our investment strategy, we use private funds designed to
capture the return behavior of entire asset classes. This differs from a traditional
passive management approach in which indexes are merely replicated. Rather than
simply tracking traditional market indexes, we use funds that are designed to capture
specific dimensions of risk identified by financial science.

We rebalance our client accounts back to their original asset allocation when they
stray more than 20% from their target for each asset class. This discipline enables us
to buy low and sell high without the need to forecast the movement of the markets,
and allows our clients to use market volatility to their long-term advantage.
The investment strategy for each client is based on their asset allocation documented
in their individual Investment Policy Statement. Decisions to buy or sell investments
are made at the individual client account level, in order to address cash flow and tax
considerations.

When transitioning a client’s investment portfolio out of a concentrated stock position,
other strategies that may be used include covered option writing and limit orders.

Risk of Loss

As we work with clients to develop long-term investment plans, we educate them
about the various risks that are involved in investing. All investment securities,
including private funds, contain a risk of loss of income and principal. Clients should
not assume that future performance of any specific investment or investment
strategy, including those recommended by GL, will be profitable or achieve any
specific performance level.