Marcado Asset Management LLC

Item 5 - Fees and Compensation

 Fees
 Fees for the Retirement Plan Services (“Fees”) are negotiable depending on individual plan needs and
 circumstances, including, but not limited to the plan size, the scope of the services, the number of participants,
 etc.

 Our maximum hourly fee is $350 per hour. Our maximum fixed fee is $50,000 annually. The agreed upon fees will
 be clearly set forth in the agreement executed between us and the client. The fees charged will not exceed more
 than 2.5% of the amount of the plan assets. Comparable services may be available from other advisers for higher
 or lower fees.

Marcado Asset Management
Form ADV Part 2A Brochure

 Generally, the fees are payable monthly or quarterly in arrears or in accordance with the negotiated terms of the
 agreement executed between us and the client. One-time, project-based fees are based on a negotiated hourly
 or fixed fee and are due and payable upon completion as invoiced. The plan sponsor may elect to be invoiced
 directly for the fees or to have the fee deducted from plan assets. Other terms and payment arrangements may
 be negotiated between us and the client.

 Periods of Portfolio Inactivity: The firm has a fiduciary duty to provide services consistent with the client’s best
 interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to
 determine if any changes are necessary based upon various factors, including but not limited to investment
 performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial
 circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may
 be extended periods of time when the firm determines that changes to a client’s portfolio are neither necessary
 nor prudent. Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee will
 continue to apply during these periods, and there can be no assurance that investment decisions made by the
 firm will be profitable or equal any specific performance level(s).

 the Sponsor may terminate the services agreement within five (5) business days of executing the agreement
 without incurring a penalty or charge. Otherwise, either party may terminate the agreement upon thirty (30) days
 prior written notice to the other party. If applicable, we will be entitled to a pro-rata amount of compensation;
 or, if applicable, any unearned fees paid in advance will be refunded promptly.

 The Sponsors receiving Retirement Plan Services may pay more or less than a client might otherwise pay if
 purchasing the Retirement Plan Services separately or through another service provider. There are several factors
 that determine whether the costs would be more or less, including, but not limited to, the size of the plan, the
 specific investments made by the plan, the number of or locations of participants, the Retirement Plan Services
 offered by another service provider, and the actual costs of Retirement Plan Services purchased elsewhere. In
 light of the specific Retirement Plan Services offered by Marcado Asset Management, the Fees charged may be
 more or less than those of other similar service providers.

 All fees paid to Marcado Asset Management for Retirement Plan Services are separate and distinct from the fees
 and expenses charged by mutual funds, variable annuities, and exchange traded funds to their shareholders.
 These fees and expenses are described in each investment’s prospectus. These fees will generally include a
 management fee, other expenses, and possible distribution fees. If the investment also imposes sales charges, a
 client may pay an initial or deferred sales charge. The Retirement Plan Services provided by Marcado Asset
 Management may, among other things, assist the client in determining which investments are most appropriate
 to each client's financial condition and objectives and may provide other administrative assistance as selected by
 the client. Accordingly, the client should review both the fees charged by the funds, the fund manager, the plan’s
 other service providers, and the fees charged by Marcado Asset Management to fully understand the total
 amount of fees to be paid by the client and to evaluate the Retirement Plan Services being provided.

 While not necessarily related to the Retirement Plan Services, various vendors, product providers, distributors,
 and others may provide non-monetary compensation by paying some expenses related to training and education,
 including travel expenses, and attaining professional designations. We might receive payments to subsidize our
 own training programs. Certain vendors may invite us to participate in conferences, and online training or provide

Marcado Asset Management
Form ADV Part 2A Brochure

 us with publications that may further investment adviser representatives' and employees’ skills and knowledge.
 Some may occasionally provide us with gifts, meals, and entertainment of reasonable value consistent with
 industry rules and regulations.

 No increase in the Fees will be effective without prior written notice.

Item 7 - Types of Clients

 Our services are available to clients who are sponsors or other fiduciaries to Plans, including 401(k), 457(b), 403(b),
 and 401(a) plans. Plans include participant-directed defined contribution plans and defined benefit plans. Plans
 may or may not be subject to ERISA. We do not require a minimum asset amount for our services.