Optimal Capital Advisors LLC

Item 5: Fees and Compensation

C. Additional Client Fees Charged
All fees paid for investment advisory services are separate and distinct from the fees and
expenses charged by platform sponsors, exchange-traded funds, mutual funds, separate
account managers, private placement, pooled investment vehicles, broker-dealers, and
custodians retained by clients. Such fees and expenses are described in each exchange-traded
fund and mutual fund’s prospectus, each separate account manager’s Form ADV and Brochure
and Brochure Supplement or similar disclosure statement, each private placement or pooled
investment vehicle’s confidential offering memoranda, and by any broker-dealer or custodian
retained by the client. Clients are advised to read these materials carefully before investing.
Optimal does not utilize mutual funds that impose sales charges. A client using Optimal Capital
may be precluded from using certain mutual funds or separate account managers because they
may not be offered by the client's custodian. Please refer to the Brokerage Practices section

Item 7: Types of Clients

vi.    any company that, but for the exceptions provided for in Sections 3(c)(1) or 3(c)(7) under
       the ICA, would be an investment company (hereafter in this paragraph referred to as an
       “excepted investment company”), provided that all beneficial owners of its outstanding
       securities (other than short-term paper), determined in accordance with Section 3(c)(1)(A)
       thereunder, that acquired such securities on or before April 30, 1996 (hereafter in this
       paragraph referred to as “pre-amendment beneficial owners”), and all pre-amendment
       beneficial owners of the outstanding securities (other than short-term paper) or any
       excepted investment company that, directly or indirectly, owns any outstanding securities
       of such excepted investment company, have consented to its treatment as a qualified
       purchaser.
vii.   any natural person who is deemed to be a “knowledgeable employee” of the [fund], as
       such term is defined in Rule 3c-5(4) of the ICA; or
viii. any person (“Transferee”) who acquires Interests from a person (“Transferor”) that is (or
      was) a qualified purchaser other than the [fund], provided that the Transferee is: (i) the
      estate of the Transferor; (ii) a person who acquires the Interests as a gift or bequest
      pursuant to an agreement relating to a legal separation or divorce; or (iii) a company
      established by the Transferor exclusively for the benefit of (or owned exclusively by) the
      Transferor and the persons specified in this paragraph.
ix.    any company, if each beneficial owner of the company’s securities is a qualified purchaser.

                     Part 2A of Form ADV: Optimal Capital Advisors, LLC, Brochure