GVS Financial Group Inc

Item 5: Fees & Compensation

Investment Advisory Services:

The annual fee for portfolio management services will be charged as a percentage of assets under management either
billed quarterly in arrears based on the value of the account(s) on the last day of the previous quarter or advance at the

    ADV Part 2A – Firm Brochure                         3                                         GVS Financial Group, Inc.

beginning of each calendar quarter based on the value of the account(s) on the last day of the previous quarter,
according to the following schedule:

                                   Assets Under Management             Annual Fee %
                                         First $1 million                 1.00%
                                         Next $1 million                  0.75%
                                        Above $2 million                  0.50%

Each client fee schedule is negotiated with GVS within this range, on a client-by-client basis. Fees are deducted directly
from client accounts on a quarterly basis. Client facts, circumstances and needs determine the fee schedule. The specific
annual fee schedule will be identified in the contract between the adviser and each client. GVS has a negotiable
relationship minimum of $500,000.

Financial Planning Services:

GVS requires a non-negotiable minimum financial planning fee of $2,500. Financial planning fees will be charged on an
hourly or flat fee basis. On an hourly basis, the rate is $400 per hour. An estimate for total hours will be determined at
the start of the relationship. The hourly fee may be reduced or waived at GVS' discretion if a financial planning client
chooses to engage GVS for its portfolio management services. Flat fees typically range from $2,500 to $5,000, depending
on the nature and complexity of each client's circumstances.

Consulting Services:

General consulting services fees will be charged on an hourly basis at a rate of $400 per hour. An estimate for total hours
will be determined at the start of the consulting relationship. All fees are agreed upon prior to entering into a contract
with any client, and are due and payable upon completion of the service.

Independent Money Manager Services:

The independent money manager's advisory fees and any account minimums are determined based on the selection of
the specific independent money manager. GVS' advisory fees are separate and distinct from the fees charged by the
independent money manager. Advisory clients should refer to the independent money manager’s disclosure brochure
for information concerning any conditions for managing an account. The independent investment adviser's
management fee is disclosed in the independent investment adviser's disclosure document.

Other Fees & Expenses:

Clients may incur transaction charges for trades executed in their accounts. These transaction fees are separate from
our firm’s advisory fees and will be disclosed by the chosen custodian and may include custodian fees, mutual fund fees,
wire transfer fees, electronic fund transfer fees, mutual fund expenses, redemption fees, account opening fees, account
closing fees, overnight shipping fees, stop payment fees, transaction fees, brokerage commissions and other related
costs and expenses. Clients may also pay charges imposed directly by a mutual fund, index fund, or exchange traded
fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales charges,
mutual fund sales loads, 12b-1 fees, surrender charges, early redemption fees, variable annuity fees, IRA and qualified
retirement plan fees, and other fund expenses). GVS does not receive a portion of these fees.

All fees paid to GVS for investment advisory services are separate and distinct from the fees and expenses charged by
mutual funds to their shareholders. These fees and expenses are described in each fund's prospectus. If the fund also
imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund directly,
without the services of GVS. In that case, the client would not receive the services provided by GVS which are designed,
among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's
financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and the fees
charged by GVS to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory
services being provided.

    ADV Part 2A – Firm Brochure                          4                                         GVS Financial Group, Inc.

Termination:

A client agreement may be canceled at any time, by either party, for any reason upon receipt of 5 days written notice.
Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees
will be due and payable.

Item 7: Types of Clients

GVS offers advisory services to individuals, high net worth individuals, trusts, estates or charitable organizations and
corporations or other business entities.

GVS requires a non-negotiable minimum financial planning fee of $2,500 and a negotiable relationship minimum of
$500,000.