Invictus Timing Service Ltd

Item 5 Fees and Compensation

                            INVESTMENT SUPERVISORY SERVICES ("ISS")
                             INDIVIDUAL PORTFOLIO MANAGEMENT FEES

Our annual fees for Investment Supervisory Services are based upon a percentage of assets under
management at a rate of 1.00%. These fees include the Market Timing Service Fees discussed below.

Our fees for Investment Supervisory Services are invoiced and payable quarterly in arrears. The fees are
computed on the average daily balance of the assets under management during the calendar quarter and
invoiced at an annual rate of 1.00%. Accounts that are opened other than the first day of a quarter shall
also be invoiced in arrears based upon the average daily balance of the assets under management for the
number of days the account was open during the quarter.

Discounts, not generally available to our advisory clients, may be offered to family members and friends of
associated persons of our firm.

Limited Negotiability of Advisory Fees: Although Invictus Timing Service, Ltd. has established the fee
schedule, we retain the discretion to negotiate alternative fees on a client-by-client basis. Client facts,
circumstances and needs are considered when negotiating fees. These include the complexity of the
client’s situation, assets to be placed under management, anticipated future additional assets, related
accounts, portfolio style, account composition, and reports, among other factors. The specific fee for these
services will be identified in the contract between the adviser and the client.

Payment of Advisory Fees: Clients of Invictus Timing Service, Ltd. authorize us to invoice their
account(s) at the Custodian directly for our advisory fees. When invoicing our advisory fees, we may
group certain related accounts at the Client’s request. The Client authorizes the Custodian to pay said fees
to the Adviser from the account(s) at the Custodian upon receipt of the invoices.

                                    MARKET TIMING SERVICES FEES

Fees for Market Timing Services are included in the Investment Supervisory Services fee discussed above.

                                         GENERAL INFORMATION

Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either
party, for any reason upon receipt of 30 days’ written notice. Upon termination of the agreement of any
client from whom fees were collected in advance, the unearned fees will be promptly refunded. In
calculating a client's reimbursement of fees, we will pro rate the reimbursement according to the number of
months remaining in the billing period. Upon termination of the advisory agreement for any client who has
entered into the new agreement, we will pro rate the final fee to be invoiced based on the average daily
balance of the assets under management for the number of days the account was open during the quarter.

Mutual Fund Fees: All fees paid to Invictus Timing Service, Ltd. for investment advisory services is
separate and distinct from the fees and expenses charged by mutual funds and variable annuities to their
shareholders. These fees and expenses are described in each fund's prospectus. They will generally
include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes
sales charges, a client may pay an initial or deferred sales charge.

A client could invest in a mutual fund directly, without our services. In that case, the client would not receive
the services provided by our firm which are designed, among other things, to assist the client in determining
which mutual fund or funds are most appropriate to each client's financial condition and objectives.
Accordingly, the client should review both the fees charged by the funds and our fees to fully understand
the total amount of fees to be paid by the client and to thereby evaluate the advisory services being
provided.

Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees
and expenses charged by custodians including but not limited to, outgoing transfers, returned checks and
next day mail service fees as well as fees imposed by broker dealers, including, but not limited to, any
transaction charges imposed by a broker dealer with which an independent investment manager effects
transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this
Form ADV for additional information.

ERISA Accounts: Invictus Timing Service, Ltd. is deemed to be a fiduciary to advisory clients that are
employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement
Income and Securities Act ("ERISA"), and regulations under the Internal Revenue Code of 1986 (the
"Code"), respectively. As such, our firm is subject to specific duties and obligations under ERISA and the
Code that include among other things, restrictions concerning certain forms of compensation. To avoid
engaging in prohibited transactions, Invictus Timing Service, Ltd. may only charge fees for investment
advice about products for which our firm and/or our related persons do not receive any commissions or
12b-1 fees, or conversely, investment advice about products for which our firm and/or our related persons
receive commissions or 12b-1 fees, however, only when such fees are used to offset Invictus Timing
Service, Ltd.'s advisory fees.

Advisory Fees in General: Clients should note that similar advisory services may (or may not) be available
from other registered (or unregistered) investment advisers for similar or lower fees.

Additional Compensation: Our fees do not include brokerage commissions, transaction fees, and other
brokerage related costs and expenses that are paid by you. You may pay additional fees imposed by
custodians, brokers, and other third parties. The advisory fee does not cover charges imposed by third
...

Item 7 Types of Clients

Invictus Timing Service, Ltd. provides advisory services primarily to individuals and high net worth
individuals. We generally do not impose a minimum account value or other conditions for opening or
maintaining an account.