NDVR Inc

Fees and Compensation
                                                                               ADDITIONAL FEES AND COSTS
FEES                                                                           Collective Fund Fees and Expenses

Part 2A of Form ADV: Firm Brochure                                                                                                                      05

Investments in collective investment funds, such as mutual funds, ETFs,         margin accounts only when we believe they are beneficial for your overall
and privately offered pooled investment vehicles, such as hedge funds,          circumstances. Please refer to Item 8 – Methods of Analysis, Investment
private equity funds or other similar vehicles (collectively and together       Strategies and Risk of Loss for more information.
with mutual funds and ETFs, “Investment Funds”) generally include an
embedded expense ratio composed of an investment management fee
and/or carried interest paid to the investment adviser of the Investment        ITEM 6.
Fund and other administrative and operating expenses. Therefore, any
Client investments in Investment Funds are subject to those fees. An ex-        Performance-Based Fees and Side-
planation of the fees and expenses paid by each Investment Fund is con-
tained in that fund’s offering document. It is important to note that in        By-Side Management
recommending these investments, NDVR examines the performance and
attributes of the Investment Funds on a net-of-fees basis.                      “Performance-Based Fees” are fees that include a percentage of the cap-
                                                                                 ital gains or capital appreciation of Client investments. NDVR does not
Custodial Fees                                                                   charge performance-based fees.
As noted in Items 4 and 15, Assets are held by one or more third-party cus-
todians. The Client is solely responsible for paying for any custodial costs    “Side-by-Side Management” refers to the management of multiple ac-
of their Accounts. NDVR has no responsibility for determining or negotiat-       counts with similar investment strategies and different fee structures. An
ing the custodial costs of an Account.                                           adviser with side-by-side management has an incentive to allocate bet-
                                                                                 ter performing assets to the performance-based fee accounts rather than
Brokerage Fees                                                                   fixed or asset-based fee accounts because the adviser stands to earn a
Clients are solely responsible for all brokerage commissions and other           larger fee. Because NDVR does not charge performance-based fees, these
transaction costs, which will be charged directly to their Accounts. NDVR        side-by-side management conflicts do not arise between NDVR and our
does not receive any portion of these commissions or costs. Brokerage fees       Clients.
are set by the custodian or other broker. For additional information regard-
ing brokerage practices, please see Item 12 – Brokerage Practices, below.

ITEM 7.
Other Fees and Expenses
In addition to NDVR’s Fee and the specific fees and expenses listed above,      Types of Clients
you will bear any other expenses, liabilities, charges and costs incurred in
connection with the Services you receive under the Client Agreement, in-        We provide Wealth Optimization Services to Clients in the United States,
cluding but not limited to any commissions, transfer fees, registration fees,   including its territories and possessions. We do not apply other, specific
exchange fees, settlement fees, interest on margin loans and stamp duty,        criteria for someone to be accepted as a Client and do not have a min-
tax or other fiscal liabilities or any other transaction related expenses and   imum account size; rather, we evaluate each applicant on a case-by-
fees arising out of transactions in the Account incurred by us, or delegates    case basis. Currently, NDVR Clients are individuals and high net worth
or third parties in performing the Services under the Client Agreement.         individuals, and NDVR anticipates having additional types of Clients.

During the Account-opening process, you will provide the custodian with
written authorization to have NDVR’s Fee deducted from your Linked Cus-         ITEM 8.
tody Account and paid to us, or you will make alternative arrangements
with us regarding the payment of NDVR’s Fee. The custodian will send            Methods of Analysis, Investment
statements, at least quarterly, showing all disbursements from the Linked
Custody Account including the amount of NDVR’s Fee, (please refer to            Strategies and Risk of Loss