Grupp Financial LLC

Item 5: Fees and Compensation

A. Fee Schedule

Portfolio Management Services Fees
        Total Assets Under Management           Annual Fee

        Up to $1,000,000                        1.50%

        Excess of $1,000,000 to $5,000,000      1.25%

        Excess of $5,000,000                    1.00%

These fees are generally negotiable and the final fee schedule is set forth in the Investment
Advisory Contract.

GF uses an annualized percentage of the net market value of assets posted monthly in the
client's account by the custodian without regard to any margin balance or securities-backed
borrowing. Fees are charged monthly in advance but may be charged quarterly in GF's sole
discretion. The Investment Advisory Contract will reflect the client’s billing period.

Please see below for an example of the fee calculation formula:

       Description:     Percentage of Net Market Value is entered as an
                        annualized percentage, applied on a monthly
                        basis (12 business months are applied in this
                        calculation method).

       Assumption:      You specify 1.5% of Net Market Value as an
                        annualized percentage, and the client’s previous

                        month-ending equity is $1,000,000.

       Calculation:     Advisor client fees for the given month will be
                        1.5%*$1,000,000/12=$1,250.00.

Additionally, GF may negotiate a fixed fee schedule at GF's discretion. Under this
arrangement, GF will charge a fixed annual rate of $X for portfolio management. This fee
will be payable in equal monthly installments. The fixed fees will never exceed 1.5% of
assets under management. In the event that the fixed fee would exceed 1.5% of the
client's assets under management, GF will discount the monthly fixed fee to equate to
1/12th of 1.5% of assets under management.

Selection of Other Advisers Fees
GF may direct clients to third-party investment advisers. GF will not be compensated via
a fee share from the advisers to which it directs those clients. GF will charge its fees per
the schedule above separately from any outside manager.

Termination of Agreement
Clients may terminate the agreement without penalty, for full refund of GF’s fees, within
five business days of signing the Investment Advisory Contract. Thereafter, clients may
terminate the Investment Advisory Contract generally with thirty days’ written notice.

B. Payment of Fees

Payment of Portfolio Management Fees
Portfolio management fees are withdrawn directly from the client’s accounts with client’s
written authorization. Fees are generally paid monthly in advance, unless reflected
otherwise within the Investment Advisory Contract. This amount will be non-refundable.

Payment of Selection of Other Advisers Fees
The timing, frequency, and method of paying fees for selection of third-party managers
will depend on the specific third-party adviser selected and will be disclosed to the client
prior to entering into a relationship with the third-party advisor.

C. Clients Are Responsible For Third Party Fees

Clients are responsible for the payment of all third-party fees (e.g., custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.), unless the Client’s Investment
Advisory Contract provides otherwise. Those fees are separate and distinct from the fees
and expenses charged by GF. Please see Item 12 of this brochure regarding
broker/custodian.

       D. Prepayment of Fees

       Contracts generally require 30-day notice of either parties’ intention to terminate a contract.
       Refunds for unearned fees paid more than 30 days in advance will be returned within
       fourteen days to the client via check, or return deposit back into the client’s account. In the
       event that a contract terminates in the middle of a billing period, a refundof any amounts
       collected beyond 30 days from date of termination will be based on a prorated basis.

       E. Outside Compensation For the Sale of Securities to Clients

       Neither GF nor its supervised persons accept any compensation for the sale of securities
       or other investment products, including asset-based sales charges or service fees from the
       sale of mutual funds.

Item 7: Types of Clients

GF generally provides advisory services to the following types of clients:

           ❖   Individuals
           ❖   High Net Worth Individuals
           ❖   Corporations or Business Entities
           ❖   Trusts (including Private Family Trust Companies)

There is no account minimum.