Harbor Hills Inc

Item 5: Fees and Compensation

A. Fee Schedule

Lower fees for comparable services may be available from other sources.

Portfolio Management Fees

        Total Assets Under Management          Annual Fees
        All Assets                             1.50%

HHI uses an average of the daily balance in the client's account throughout the billing
period, after taking into account deposits and withdrawals, for purposes of determining
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 for a
full refund of HHI's fees within five business days of signing the Investment Advisory
Contract. Thereafter, clients may terminate the Investment Advisory Contract generally
with 30 days' written notice.

Performance-Based Fees for Portfolio Management

Qualified clients will pay a quarterly of 1.50% of assets under management along with a
15.00% performance fee based on capital appreciation. If the client's portfolio rises in
value, the client will pay 15.00% on that increase in value, but if the portfolio drops in
value, the client will not incur a new performance fee until the portfolio reaches the last
highest value, adjusted for withdrawals and deposits, which is generally known as a “high
water mark.”

The high water mark will be the highest value of the client’s account on the last day of any
previous quarter, after accounting for the client’s deposits or withdrawals for each billing
period.

These fees are generally negotiable and the final fee schedule will be memorialized in the
client’s advisory agreement. This service may be canceled with 30 days’ notice. Clients
must pay the prorated performance-based fees for the billing period in which they
terminate the Investment Advisory Contract up to and including the day of termination.

Financial Planning Fees

Hourly Fees

The negotiated hourly fee for these services is between $200 and $500.

Clients may terminate the agreement without penalty, for full refund of HHI’s fees, within
five business days of signing the Financial Planning Agreement. Thereafter, clients may
terminate the Financial Planning Agreement generally upon written notice.

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Asset-based portfolio management fees are withdrawn directly from the client's accounts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

Payment of Performance-Based Portfolio Management Fees

Performance-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 arrears.

Payment of Financial Planning Fees

Financial planning fees are paid via check and wire.

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

D. Prepayment of Fees

HHI collects its fees in arrears. It does not collect fees in advance.

       E. Outside Compensation For the Sale of Securities to Clients

       Neither HHI 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.

Item 7: Types of Clients

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

       ❖      Individuals
       ❖      High-Net-Worth Individuals

There is no account minimum for any of HHI’s services.