Octavia Investments LLC

Item 5: Fees and Compensation

      A.      Fee Schedule

      Investment Supervisory Services Fees

Total Net Funds Deposited    Market Index   Active Index    Income        Atlas      Unconstrained
       with Octavia           Annual Fee    Annual Fee     Annual Fee   Annual Fee    Annual Fee
    Up to $499,999              0.35%         0.55%          0.55%        1.50%         1.50%

 $500,000 to $999,999           0.30%         0.50%          0.50%        1.25%         1.25%

      $1,000,000+               0.25%         0.45%          0.45%        1.00%         1.00%

      These fees are negotiable depending upon the needs of the client and complexity of the
      situation. Fees are calculated quarterly based on the closing value of the account on the
      final day of each quarter. Clients may terminate the contract without penalty, for full
      refund, within five business days of signing the contract. Thereafter, clients may terminate
      the contract with one day written notice. Fees are deducted or invoiced quarterly
      following the completion of the March, June, September and December quarters.

      For contracts begun or terminated during a quarter, fees for such quarter are calculated
      on a prorated basis, based on the number of days completed in the quarter at the time of
      account commencement or termination. The fee due will be (1) the start or termination
      date closing prices AUM times (2) the daily rate* times (3) the number of days in the
      quarter (i) through the end of the quarter for new accounts or (ii) up to and including the
      day of termination for terminated accounts. (*The daily rate is calculated by dividing the
      annual AUM fee percentage by 365 days). The invoiced fee will include all fees incurred
      during the quarter up until the termination date. Lower fees for comparable services may
      be available from other sources.

      The fee % in the above table are based on the total net funds deposited with Octavia across
      all client accounts, not the AUM across all client accounts. The fee amount charged by
      Octavia, though, is based on AUM, not total net funds deposited.

      B.      Payment of Fees

      Payment of Investment Supervisory Fees

      Depending on the brokerage firm used by the Client, advisory fees either will be invoiced
      and billed directly to the client quarterly at the end of the quarter or will be deducted
      directly from the Client account quarterly at the end of the quarter. Quarters end in
      March, June, September and December. In the case where advisory fees are deducted

       directly from the Client account, this will only occur if the Client has given prior written
       approval to do so and Client will have access to monthly statements from the Client’s
       brokerage firm showing the amount of the fees being deducted. OI will also provide Client
       a quarterly statement prepared by OI with the calculation of fees, which will serve as a fee
       invoice.

       C.       Clients Are Responsible For Third Party Fees

       Clients are responsible for the payment of all third party fees (i.e. custodian fees,
       brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
       distinct from the fees and expenses charged by OI. Please see Item 12 of this brochure
       regarding broker/custodian.

       D.       Prepayment of Fees

       OI does not collect fees in advance.

       E.       Outside Compensation For the Sale of Securities to Clients

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

Item 7: Types of Clients

OI generally provides management supervisory services to the following types of clients:

            ❖   Individuals
            ❖   High-Net-Worth Individuals
            ❖   Trusts and estates
            ❖   Family offices
            ❖   Corporations

Minimum Account Size

There is no account minimum.