Hafele Investments Inc

Item 5: Fees and Compensation

A. Fee Schedule

Portfolio Management Fees

        Total Assets Under Management          Annual Fees
        All Assets                             Up to 1.00%

The balance in the client’s account on the last day of the previous quarter end is used to
determine the market value of the assets upon which the advisory fee is based.

These fees are generally negotiable, and the final fee schedule will be memorialized in the
client’s advisory agreement. Clients may terminate the agreement without penalty within
five business days of signing the Investment Management Agreement. Thereafter, clients
may terminate the Investment Management Agreement immediately upon written notice.

Financial Planning Fees

Fixed Fees

The negotiated fixed rate for creating client financial plans is between $1,000 and $25,000.

Clients may terminate the agreement without penalty within five business days of signing
the Financial Planning Agreement. Thereafter, clients may terminate the Financial
Planning Agreement generally upon written notice.

Portfolio Management Fees to Private Funds

HFM, a wholly owned subsidiary of HI, serves as Managing Member of private funds.

The fees and expenses associated with such funds are described in the applicable offering
documents. Investors bear their proportionate share of fund-level fees and expenses as
described in those documents.

HI may recommend investments in these funds to advisory clients. Because HI receives
economic benefits from compensation earned in connection with these funds, a conflict of
interest exists when such investments are recommended.

HI does not charge its standard advisory fee on client assets invested in such funds.
Accordingly, clients are not charged both an advisory fee and a fund-level management
fee on the same invested assets.

B. Payment of Fees

Payment of Portfolio Management Fees

Asset-based portfolio management fees are withdrawn directly from the client's accounts
with client's written authorization on a quarterly basis, or may be invoiced and billed
directly to the client on a quarterly basis. Clients may select the method in which they are
billed. Fees are paid in advance.

Payment of Financial Planning Fees

Financial planning fees are paid via check and wire.

Fixed financial planning fees are paid in arrears upon completion.

C. Client Responsibility For Third Party Fees

Clients are responsible for the payment of all third party fees (i.e. custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and

       distinct from the fees and expenses charged by HI. Please see Item 12 of this brochure
       regarding broker-dealer/custodian.

       D. Prepayment of Fees

       As disclosed above, certain fees, depending on the client agreement, are paid in advance
       of services provided. Upon termination of any account, any prepaid, unearned fees will
       be promptly refunded. In calculating a client's reimbursement of fees, we will pro rate the
       reimbursement according to the number of days remaining in the billing period.

       E. Outside Compensation For the Sale of Securities to Clients

       Neither HI 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

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

       ❖       Individuals
       ❖       High-Net-Worth Individuals
       ❖       Pooled Investment Vehicles

There is no account minimum for any of HI’s services. There is a minimum investment
commitment of $100,000 in the private funds managed by HFM.