Lotus Asset Management Limited Liability Company

Item 5: Fees and Compensation

A. Fee Schedule

Lower fees for comparable services may be available from other sources.

Asset-Based Fees for Comprehensive Financial Advisory Services and Held-
Away Account Services

The Firm’s current standard advisory fee schedule is described above. However, certain
legacy clients who entered into advisory agreements prior to changes in the Firm’s fee
structure may be subject to different fee arrangements, including lower asset‑based fees,
capped fees, or flat‑fee arrangements. These legacy arrangements are maintained
pursuant to the terms of each client’s advisory agreement and may differ from the fees
currently charged to new clients for similar services. Legacy fee arrangements are
generally not available to new clients. The Firm may, in its discretion, negotiate fees based
on factors such as account size, complexity of services provided, and the client’s
relationship with the Firm.

Comprehensive Financial Advisory Package ($15,000 minimum annual fee. Clients whose
assets do not meet a $15,000 minimum from a AUM based fee will be charged a $15,000
annual baseline fee)

        Total Assets Under Management          Annual Fee

        $0-$2,000,000                          1.00%

        $2,000,001 - $5,000,000                0.75%

        $5,000,001-$25,000,000                 0.50%

        $25,000,001 and UP                     0.25%

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 LAM's fees within five business days of signing the Investment

Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract
immediately upon written notice. This is a blended tier schedule.

In the case that fees are charged in advance, LAM uses the value of the account as of the
last business day of the prior 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.

Financial Planning Services are included for all Comprehensive Financial Advisory
Services clients at no additional cost.

Due Diligence and Monitoring of Alternative Investments Fees

        Total Assets Under Management          Annual Fee

        All Assets                             1.00%

Financial Planning Fees

Fixed Fees

The rate for creating client financial plans is between $3,000 and $75,000. The fees are
negotiable and the final fee schedule will be attached as Exhibit II of the Financial
Planning Agreement.

Clients may terminate the agreement without penalty, for full refund of LAM’s fees,
within five business days of signing the Financial Planning Agreement. Thereafter, clients
may terminate the Financial Planning Agreement with upon written notice.

B. Payment of Fees

Payment of Comprehensive Financial Advisory Services Fees

Comprehensive Financial Advisory Services fees are withdrawn directly from the client's
accounts with client's written authorization on a monthly basis. Client will be billed either
in advance or arrears, according to the custodian being used. This will be discussed and
agreed upon in the client contract.

Held Away Account Services Fees

The current exception for this is directly-managed held-away accounts, such as 401(k)s,
which are determined by the account value at the end of the quarter. Directly debiting
fees from such accounts may have negative tax consequences. Therefore, fees for those
accounts will be assigned to the client’s taxable accounts on a pro-rata basis. If the client
does not have a taxable account, those fees will be billed directly to the client. Accounts
initiated or terminated during a calendar quarter will be charged a pro-rated fee based on

       the amount of time remaining in the billing period. An account may be terminated with
       written notice at least 15 calendar days in advance. Since fees are paid in arrears, no rebate
       will be needed upon termination of the account.

       Due Diligence and Monitoring of Alternative Investments Fees

       Due Diligence and Monitoring of Alternative Investments Fees are withdrawn directly
       from the client's accounts with client's written authorization on a quarterly basis. If fees
       are not able to be withdrawn directly from the alternative investment account, fees for
       those accounts will be assigned to the client's taxable accounts on a pro-rata basis.

       Payment of Financial Planning Fees

       Fixed Financial Planning fees are invoiced and payable via cash, check, or wire. Fees are
       due in advance. LAM will not collect fees in excess of $500 for services to be rendered
       more than six months in advance.

       C. Client Responsibility for Third Party Fees

       LAM will combine third party fees (i.e. custodian fees, brokerage fees, mutual fund fees,
       transaction fees, etc.). LAM will charge clients one fee, and pay all transaction fees using
       the fee collected from the client.

       D. Prepayment of Fees

       In the case that fees are collected in advance, refunds for fees paid in advance will be
       returned within fourteen days to the client via check, or return deposit back into the
       client’s account.

       For all asset-based fees paid in advance, the fee refunded will be equal to the balance of
       the fees collected in advance minus the daily rate* times the number of days elapsed in
       the billing period up to and including the day of termination. (*The daily rate is calculated
       by dividing the annual asset-based fee rate by 365.)

       E. Outside Compensation for the Sale of Securities to Clients

       Neither LAM nor its supervised persons accept any compensation for the sale of securities
       or other investment products, including asset-based sales charges or service fees from the
...

Item 7: Types of Clients

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

           ❖ Individuals
           ❖ High-Net-Worth Individuals
           ❖ Charitable Organizations

Minimum Account Size

There is an account minimum of $500,000, which may be waived by LAM at its discretion if
household income or other extenuating circumstances are a factor.