Harbor Investment Advisory LLC

ITEM 5: FEES AND COMPENSATIONS
Harbor is compensated through an annualized asset-based fee (referred to as “Advisory Fee”, “Client Fee” or
“Wrap Fee” depending on the Advisory Program selected by the Client), which will be paid monthly or quarterly
in arrears, as indicated in the table below. The amounts and specific manner that fees are charged is memorialized
in our Advisory Agreement with the Client. Although many fees are individually negotiated, the range of Harbor’s
Advisory Fees are described below:

              Harbor Program                                      Fee Range *                                 When Charged

   Harbor Manager Select                                         0.25% - 2.00%                               Monthly in Arrears

   Harbor Investment Consulting                                  0.25% - 1.50%                               Monthly in Arrears

   Retirement Plan Services                        Flat Fee, Hourly Fee, and/or Fee on Assets          Monthly or Quarterly in Arrears

   Financial Planning Services                     Flat Fee, Hourly Fee, and/or Fee on Assets           Varies by Engagement Letter

           * Computed as a percentage of assets under management in the Account including any margin debit in the Account.

Advisory Fees are deducted from your Account within twenty (20) business days of the end of the period for
which the fees are incurred. The Advisory Fee for the initial monthly period shall be charged pro rata from the
funding date of the Account based on the number of days services were provided, and the value of the Assets held
in the Account at the end of the initial monthly period. Upon termination of an Account, any earned, unpaid
Advisory Fees will be due and payable.

In addition to the Advisory Fee, Clients will incur, directly or indirectly, other fees and expenses for investments
made for the Client. Harbor refers some Clients to providers of investment offerings for which Harbor and/or its
employees receive selling and/or placement compensation, in addition to the Advisory Fee, which are credited
back to the Client or used to reduce the Client’s Advisory Fee. Harbor does not, in its capacity as introducing
broker for Advisory Clients’ Accounts, charge brokerage commissions on transactions placed in Advisory
Accounts. Custody fees imposed on IRA accounts are waived for Advisory Accounts. Other administrative fees
charged for wire transfers and check writing services are not included in the Advisory Fee. Harbor may
unilaterally amend certain fees affecting all Harbor Clients upon thirty (30) day written notice of the change and
without Client having to execute a new Advisory Agreement.

 Harbor Investment Advisory, LLC                                                                                       Page 6 of 15
 Form ADV Part 2A Firm Brochure 03/31/26

By investing with certain third-party money managers and/or by making direct investments, Client will incur fees,
brokerage commissions, transaction fees, manager’s fees, custody fees, and other related costs and expenses.
Such third-party charges, fees and commissions are exclusive of and in addition to Harbor’s Advisory Fee.

Additionally, Clients will indirectly incur certain fees and expenses for investments made for the Account in
mutual funds, ETFs, money market funds, variable annuities and other Assets. Fund fees and expenses are
paid by the fund and are borne by all fund shareholders owning the same class of share. The fees and expenses
can include, but are not limited to, mutual fund servicing fees, sub-accounting fees, management fees, custody,
portfolio transaction execution costs, administration fees, distribution fees, and shareholder servicing fees. Fees
and expenses charged by funds are deducted from each fund's net asset value, while annuity expenses are
deducted from the value of the annuity by the annuity issuer, and as such, these are indirect expenses of the
Client. When Harbor recommends or places an annuity in an Advisory Account, neither Harbor nor its
representatives receive a commission. These types of investments can be purchased directly without being
managed by Harbor pursuant to this Agreement, which may cost you more or less.

Harbor receives mutual fund distribution and servicing fees from certain mutual fund companies, depending on
the class of shares held. Harbor credits to the Client, or applies it to reduce the Client’s Advisory fee, all payments
received from any fund on account of Client’s advisory holdings. Clients should be aware that when we place a
transaction on your behalf, we attempt to place Clients in the most cost-effective share class available at that
time. Since fund companies can add new share classes at any time, without offering or executing an automatic
exchange from existing share classes of the same fund, it is possible that the class originally selected may no
longer be the most cost-effective class available. As set forth below, Harbor offers all Clients an annual review
of their account and holdings and the share class selections are among the topics that will be covered in the
review. For a complete description of the fees and expenses related to each investment, Client should review
the prospectus for the respective mutual fund, ETF, money market fund, and other Assets.

For fixed income securities transactions, Clients will indirectly incur certain fees and expenses for transactions
effected through a broker-dealer other than Pershing from the commission or mark-up/down that is included in
the net purchase price or sale proceeds of the security. Harbor does not receive any portion of these fees or
expenses, so they will not be credited back to Client’s investment Account or used to reduce the Client’s Advisory
Fee.

A Client’s Advisory Account can hold certain Assets that are not supervised by Harbor and are not charged an
...

ITEM 7: TYPES OF CLIENTS
Clients include ultra-high net worth and high net worth individuals, their families, family offices and related entities
such as trusts, estates, private foundations, as well as pension, profit sharing and other retirement plans,
charitable organizations, corporations, and other business entities. Clients receive ongoing personalized
investment advice and guidance from their Harbor Financial Advisor.

 Harbor Investment Advisory, LLC                                                                       Page 8 of 15
 Form ADV Part 2A Firm Brochure 03/31/26

Retirement Investors
When we provide investment advice to you regarding your retirement plan Account or individual retirement
Account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or
the Internal Revenue Code, as applicable, which are laws governing retirement Accounts. The way we make
money creates some conflicts with your interests, so we operate under a special rule that requires us to act in
your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must; (i) meet
a professional standard of care when making investment recommendations (give prudent advice), (ii) never put
our financial interests ahead of yours when making recommendations (give loyal advice), (iii) avoid misleading
statements about conflicts of interest, fees, and investments, (iv) follow policies and procedures designed to
ensure that we give advice that is in your best interest, (v) charge no more than is reasonable for our services
and, (vi) give you basic information about conflicts of interest.