Kinwell LLC

Item 5: Fees and Compensation

A. Fee Schedule

Portfolio Management Fees

        Standard Portfolio Management Fees

                   Total Assets Under Management                       Annual Fees
                             First $2,000,000                              0.90%

                      Next $2,000,001 - $5,000,000                         0.68%

                       Next $5,000,001 and Above                           0.50%

        Kinwell uses a blended fee structure as noted above. For the first $2,000,000 you will pay 0.90%
        on those assets. On any assets in the account above $2,000,000 that are between $2,000,001 and
        $5,000,000 you will pay 0.68% on that portion of the assets in the account. On any assets above
        $5,000,000 you will pay 0.50% on that portion of the assets in the account. For example, on an
        account with $3,500,000 you will be charged 0.90% on $2,000,000 and 0.68% on $1,500,000.
        Kinwell uses the value of the account as of the last business day of the billing period for determining
        the market value of the assets upon which the advisory fee is based.

        Portfolio Management Fees for Business Entity Accounts

        Kinwell may establish accounts for business entities, which will be invested in money market
        instruments and low-duration bonds. These accounts will be subject to an annual management fee
        of 0.45% (45 basis points) of assets under management. Fees are calculated based on the account
        balance as of the final business day of each quarter and are charged quarterly in arrears. The fee is
        deducted directly from the client’s account.

These fees are generally negotiable, and the final fee schedule is attached as Exhibit II of the Investment
Advisory Contract. Clients may terminate the agreement without penalty for a full refund of Kinwell's fees
within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate
the Investment Advisory Contract immediately upon written notice.

Pension Consulting Services Fees

        Asset-Based Fees for Pension Consulting

                   Total Assets Under Management                        Annual Fee
                        $2,500,000 - $4,999,999                            0.55%

                        $5,000,000 - $9,999,999                            0.45%

                         $10,000,000 - AND UP                              0.40%
             *Retirement plan consulting fees may be a combination of flat fee plus asset-based fees.

        Kinwell will not provide pension consulting services to clients with assets under $2,500,000.
        Kinwell uses the value of the account as of the last business day of the billing period for determining
        the market value of the assets upon which the advisory fee is based.

        Fixed Fees for Pension Consulting

        The rate for creating client pension consulting plans is between $25,000 and $150,000.
             *Retirement plan consulting fees may be a combination of flat fee plus asset-based fees.

The final fee schedule will be attached as Exhibit II of the pension consulting agreement. Clients may
terminate the agreement without penalty for a full refund of Kinwell's fees within five business days of
signing the pension consulting agreement. Thereafter, clients may terminate the pension consulting
agreement immediately upon written notice.

B. Payment of Fees

Payment of Standard 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. Fees are paid in arrears.

Payment of Pension Consulting Fees

Asset-based pension consulting fees are withdrawn directly from the client's accounts with client's written
authorization on a quarterly basis. Fees are paid in arrears.

Fixed pension consulting fees are paid via check. These 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 from, and in addition to, the fees and expenses
charged by Kinwell. Please see Item 12 of this brochure regarding broker-dealer/custodian.

D. Prepayment of Fees

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

E. Outside Compensation For the Sale of Securities to Clients

Neither Kinwell 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
Kinwell generally provides advisory services to the following types of clients:

    •   Individuals
    •   High-Net-Worth Individuals
    •   Pension and Profit-Sharing Plans