KURE Advisory LLC

Item 5. Fees and Compensation
         Kure Advisory offers services on a fee basis, which includes fixed fees, as well as fees based upon assets
         under management. Additionally, certain of the Firm’s Supervised Persons, in their individual capacities,
         offer insurance products under a separate commission-based arrangement.

         Financial Planning and Consulting Fees

         Kure Advisory charges a fixed fee for providing financial planning and consulting services. This can be
         done as part of a wealth management or stand-alone engagement. These fees are negotiable, but range from
         $500 to $10,000, depending upon the scope and complexity of the services and the professional rendering
         the financial planning and/or the consulting services. The fee can be for a defined project, such as the
         delivery of a plan, or for ongoing services. If the client engages the Firm for additional investment advisory
         services, Kure Advisory can offset all or a portion of its fees for those services based upon the amount paid
         for the financial planning and/or consulting services.

         The terms and conditions of the financial planning and/or consulting engagement are set forth in the
         Advisory Agreement. For project-based services Kure Advisory requires the full fee payable upon
         execution of the Advisory Agreement. Ongoing services are charged as described in the investment
         management section, below. The Firm does not, however, take receipt of $1,200 or more in prepaid fees,
         six or more months in advance of services rendered.

         Investment Management Fees

         Kure Advisory offers investment management services for an annual fee based on the amount of assets
         under the Firm’s management. This management fee varies between 50 and 150 basis points (0.50% –
         1.50%), depending upon the size and composition of a client’s portfolio, the type and amount of services
         rendered and the individual(s) providing the services.

         The annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets

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Disclosure Brochure

  Disclosure Brochure                                                                              Kure Advisory
         being managed by Kure Advisory on the last day of the previous quarter as determined by a party
         independent from the Firm (including the client’s custodian or another third-party). If assets in excess of
         $50,000 are deposited into or withdrawn from an account after the inception of a billing period, the fee
         payable with respect to such assets is adjusted to reflect the interim change in portfolio value. For the initial
         period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory agreement is
         terminated, the fee for the final billing period is prorated through the effective date of the termination and
         the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate.

         The Firm includes cash in a clients account in determining the valuation for billing purposes. The Firm
         may, in its sole discretion, not include cash in determining the fee, especially where a client has a high
         percentage of cash for reasons other than the Firm's investment management decision. Additionally, for
         asset management services the Firm provides with respect to certain client holdings (e.g., held-away assets,
         accommodation accounts, alternative investments, etc.), Kure Advisory can negotiate a fee rate that differs
         from the range set forth above. Clients are advised that a conflict of interest exists for the Firm to
         recommend that clients engage Kure Advisory for additional services for compensation, including rolling
         over retirement accounts or moving other assets to the Firm’s management. Clients retain absolute
         discretion over all decisions regarding engaging the Firm and are under no obligation to act upon any of the
         recommendations.

         Fee Discretion

         Kure Advisory may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such
         as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be
         managed, related accounts, account composition, pre-existing/legacy client relationship, account retention,
         pro bono activities, or competitive purpose.

         Additional Fees and Expenses

         In addition to the advisory fees paid to Kure Advisory, clients also incur certain charges imposed by other
         third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions
         (collectively “Financial Institutions”). These additional charges include securities brokerage commissions,
         transaction fees, custodial fees, fees attributable to alternative assets, margin and other borrowing costs,
         charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus
         (e.g., fund management fees and other fund expenses), 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. The Firm’s brokerage practices are described at length in Item 12, below.

         Direct Fee Debit

         Clients provide Kure Advisory and/or certain Independent Managers with the authority to directly debit
         their accounts for payment of the investment advisory fees. The Financial Institutions that act as the
         qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees,

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Disclosure Brochure
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Item 7. Types of Clients
         Kure Advisory offers services to individuals, trusts, estates, corporations and other business entities.

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Disclosure Brochure

  Disclosure Brochure                                                                          Kure Advisory