Harbourfront Wealth America Inc

Item 5: Fees and Compensation

A. Fee Schedule

Portfolio Management Fees

        Total Assets Under Management           Annual Fees
        All Assets                              Up to 2.50%

Similar services may be available at a lower price.

HWAI 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 HWAI's fees within five business days of signing the Investment Advisory
       Contract. Thereafter, clients may terminate the Investment Advisory Contract
       immediately 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       Asset-based portfolio management fees are withdrawn directly from the client's accounts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 monthly basis. Fees are paid in arrears.

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

       D. Prepayment of Fees

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

       E. Outside Compensation For the Sale of Securities to Clients

       Calder Ellis Ashton, Kim Thompson, and Zoheb Somani are management persons of
       Harbourfront Wealth Management Inc. They do not accept compensation for the sale of
       securities.

Item 7: Types of Clients

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

       ❖      Individuals
       ❖      High-Net-Worth Individuals
       ❖      Private Corporations

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