HARA Capital LLC

Item 5: Fees and Compensation

     Fees Based on Assets Under Management

     Hara is a fee-only advisory firm, meaning it does not receive commissions. Hara believes this
     method of compensation minimizes conflicts of interest.

     For all assets, Hara will charge up to 1% of assets. These fees are generally negotiable based on
     client specific factors, and the final fee schedule will be memorialized in the client’s advisory
     agreement. Clients may terminate the agreement without penalty upon written notice.

     Hara uses the balance in the client’s account on the last day of the billing period for purposes of
     determining the market value of the assets upon which the advisory fee is based.

     For partial billing periods, the fees will be prorated based upon the number of days the account
     was open during a billing period.

     In computing the market value of any investment of the Account, the securities in the Account
     listed on a national securities exchange or otherwise subject to current last-sale reporting shall
     be valued at the amount reported on the statement that Client receives from the Custodian. Such
     securities which are not traded nor subject to last-sale reporting shall be valued at the latest
     available bid price reflected by quotations furnished to Hara by such sources as it may deem
     appropriate. Any other security shall be valued in such manner as determined by Hara and Client,
     consistent with Hara’s fiduciary duty, to reflect the security’s fair market value. Client may dispute
     valuations with Hara if Client disagrees, at which point Client and Hara will discuss the valuation
     in order to promptly resolve the dispute.

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

     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     Asset-based portfolio management fees are withdrawn directly from the client's accounts with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. Fees are paid in arrears.

     Hara collects its fees in arrears. It does not collect any fees in advance.

     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 Hara. Please see Item 12 of this brochure regarding broker-dealer/custodian.

Item 7: Types of Clients
     Hara provides advisory services to the following types of clients:

     -   Individuals, including High-Net-Worth Individuals
     -   Trusts and estates
     -   Corporations or Business Entities including Charitable Foundations

     Hara generally requires a minimum account size of $5 million. Minimum account size may be
     waived for certain clients at Hara’s discretion.