Horn Eichenwald Investments Corp

Item 5 – Fees and Compensation
The specific way fees are charged by HEIC is established in a client’s written agreement
with HEIC. All fees are subject to negotiation with each client.
For its investment management services, HEIC may charge a management fee consisting
of a percentage of the assets under management, and for qualifying accounts a
performance fee consisting of a percentage of the profits over a predetermined
benchmark.
Each quarter/semester the management fee will be calculated on the initial value of the
investment account of the period. The fee will be billed in arrears and payable within 30
days after the end of each period. Fees will be prorated upon establishment of the
investment account and upon termination of the investment account. Termination of the
account shall be effective within fifteen days of receipt of written notice. Performance fees
paid are not refundable. All accounts have a high-water mark that lasts 12 consecutive
months, measured either on a quarterly or semester basis.
HEIC may charge the following fees unless a principal approves alternate fee structure:
   •   Fixed fee of 0.25% per annum and performance fee of 10% of the return in
       excess of 6 month LIBOR, for qualifying accounts or;
   •   Fixed fee of up to 2% of annum.
HEIC’s fees are exclusive of brokerage commissions, transaction fees, and other related
costs and expenses, which shall be incurred by the client. Clients may incur certain
charges imposed by custodians, brokers, third party investment and other third parties
such as fees charged by managers, custodial fees, deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and
taxes on brokerage accounts and securities transactions. Mutual funds and exchange-
traded funds also charge their own internal management fees, which are disclosed in a
fund’s prospectus. Such charges, fees, and commissions are exclusive of and in addition
to HEIC’s fee, and HEIC shall not receive any portion of these commissions, fees, and
costs.

Item 12 further describes the factors that HEIC considers in suggesting broker-dealers
for client transactions and determining the reasonableness of their compensation (e.g.,
commissions)

All financial planning fees are determined by the qualified professional that enters into an
agreement with HEIC’s client. HEIC does not receive any commissions or rebates for
any financial planning services fees charged to its clients.

Item 7 – Types of Clients
HEIC provides investment management and advisory services as well as financial
planning services through indications for both onshore and offshore high net worth
individuals, pooled investment vehicles, corporations, and other business entities.
Approximately 100% of HEIC’s clients are non-US residents. The minimum account size
to open an account at HEIC is $250,000. Accounts opening with less than $250,000 may
be accepted upon the discretion of the Directors or Management.

HEIC may visit their offshore clients in their residing country throughout the year. Many
offshore clients wish to not receive or to have their mail held by an unrelated third party
due to security concerns in their country. HEIC has developed alternative solutions for
their offshore clients to receive their quarterly statements and reports.