Ninth Eternity Asset Management LLC

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

Page | 7

 Disclosure Brochure

      Wealth Management Fees

      NEAM offers comprehensive investment management services for an annual fee based on the amount of
      assets under the Firm’s management as described below:

       Asset Size                                        Fee
       Between $200,000 to $1,000,000                    0.90%
       Above $1,000,000                                  0.80%

      The annual fee is prorated and charged daily, monthly or quarterly, in advance, based upon the market value
      of the assets being managed by NEAM on the last day of the previous day, month or quarter. If assets 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      deposited into or withdrawn from an account after the inception of a billing period, the fee payable with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.

      Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g.,
      held-away assets, accommodation accounts, alternative investments, etc.), NEAM may negotiate a fee rate
      that differs from the range set forth above.

      Financial Planning and Consulting Fees

      For financial planning and consulting services that fall outside of the Firm’s wealth management services,
      NEAM charges a fixed fee. These fees are negotiable but range from $1,000 to $50,000 depending upon
      the scope and complexity of the services and the professional rendering the financial planning and/or the
      consulting services. If the client engages the Firm for additional investment advisory services, NEAM may
      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 and NEAM requires one-half of the fee (estimated hourly or fixed) payable upon
      execution of the Advisory Agreement. The outstanding balance is due upon delivery of the financial plan
      or completion of the agreed upon services. The Firm does not, however, take receipt of $1,200 or more in
      prepaid fees more than six months in advance of services rendered.

Page | 8

 Disclosure Brochure

      Retirement Plan Consulting Fees
      NEAM charges fixed project-based fee or asset-based fee to provide clients with retirement plan consulting
      services. Each engagement is individually negotiated and tailored to accommodate the needs of the
      individual plan sponsor, as memorialized in the Agreement. These fees vary, based on the scope of the
      services to be rendered, including the amount of assets to be managed.

      Fee Discretion

      NEAM 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
      and pro bono activities.

      Additional Fees and Expenses

      In addition to the advisory fees paid to NEAM, 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 charged by the Independent Managers and the UMA platforms used to
      access them, 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 NEAM 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, have agreed
      to send statements to clients not less than quarterly detailing all account transactions, including any amounts
      paid to NEAM.

      Use of Margin

      NEAM does not recommend that clients utilize margin or other borrowing in managing client assets. The
      Firm will, however, when requested by clients, facilitate borrowing needs through margin, securities based-
      lending for cash and liquidity needs.

Page | 9

 Disclosure Brochure

      If a client requests that the Firm purchase a securities position on margin or sell a security short, the Firm
      will evaluate the request considering the client’s objectives and circumstances, and if the Firm determines
      that the investment is consistent with the client’s best interests, the Firm will manage that position. In these
...

Item 7. Types of Clients
      NEAM offers services to individuals, high net worth individuals, pension and profit-sharing plans, trusts,
      estates, charitable organizations, corporations and business entities.

      Minimum Account Fee

      As a condition for starting and maintaining an investment management relationship, NEAM imposes a
      minimum quarterly fee of $1,250.
      This minimum fee will cause clients with smaller portfolios to incur an effective fee rate that is higher than
      the Firm’s stated fee schedule. NEAM may, in its sole discretion, elect to waive its minimum fee based
      upon certain criteria, including anticipated future earning capacity, anticipated future additional assets,
      dollar amount of assets to be managed, related accounts, account composition, pre-existing client, account
      retention, and pro bono activities.

Page | 10

 Disclosure Brochure