Pento Portfolio Strategies LLC

Item 5: Fees and Compensation

      A. Fee Schedule for Retail Clients
      Investment Supervisory Services Fees

Maximum Asset Management Fees:

                   Assets Under PPS                                    Annual Fee

                     Up to $749,999                                      1.50%

                   $750,000 - $999,999                                   1.25%

            $1,000,000 and above                              1.00%

Minimum Opening Account Size -$100,000 which can be waived at PPS’s sole discretion.
PPS combines client and household accounts to determine break-points. Aggregation is
common and by not doing so can lead to higher fees. For accounts that are not in the
actively managed IDEC Model known as Global Yield P (GY) PS charges a reduced fee of
.5%

Investment Supervisory Services - These fees and amounts are negotiable
depending upon the needs of the client and complexity of the situation and
the final fee schedule is attached as Exhibit II of the Investment Advisory
Contract. Lower fees for comparable services may be available from other sources.
Fees are paid quarterly in advance, based on the value of the client's account of the last
business day of the prior quarter. Clients may terminate their contracts at any time by
phone or email. Refunds are given on a prorated basis, based on the number of days
the account is open during the final quarter. The fee refunded will be the balance of
the fees collected in advance minus the daily rate* times the number of days in the
quarter up to and including the day of termination. (*The daily rate is calculated
by dividing the quarterly AUM fee by the number of days in the termination
quarter). Clients may terminate their contracts within five days of signing the
contract without fee or penalty by written notice to the firm.

Advisory fees are withdrawn directly from the client’s accounts with client written
authorization, Only clients who are prohibited from paying fees through their account
can pay by other means such as a check. In all instances, the Adviser will make
available upon request a written invoice, including the fee, the formula used to
calculate the fee, the fee calculation itself, the time period covered by the fee, and, if
applicable, the amount of assets under management on which the fee was based. We
urge the client to review the fee listed in the account statement and reach out if they
believe there is a discrepancy. In computing the market value of any investment of the
Account, each security listed on any national securities exchange or otherwise subject to
current last-sale reporting shall be valued at the value reported on the statement that
clients receive from the custodian.

Subscription Service Fees - After a 5 week free trial subscription, PPS offers listeners
of it Mid-Week Reality Check a one-year subscription for $50, collected in advance,
payable by PayPal or by check. Refunds will be calculated on a pro-rates basis based
on the number of days used/number of days in the year. PPS Clients receive this service
for free.

Real Time Reality Alert - Fees are either a flat fee of $250 a quarter for accounts

under $1 million dollars and are a flat fee of $5,000 for accounts over $1 million - this
fee is nonnegotiable. These services will be billed on a quarterly basis in advance.
Refunds will be calculated on a pro-rated basis based on the number of days
used/number of days in the quarter. If the client terminates before any information is
provided they would be entitled to a full refund which would be sent to them via check
or PayPal, or other negotiated means.

Participant Account Management - Clients under the Account Management
arrangement are billed at the same fee structure as ISS Clients and billed quarterly in
advance following the same rules as Investment Supervisory Services (ISS).

B. Payment of Fees

Payment of Investment Supervisory Fees

Advisory fees are withdrawn directly from the client’s accounts with client written
authorization. Fees are paid quarterly in advance.

Payment of Fees for Tax and Advisory Services

Tax and Accounting fees are determined on a client-by-client basis, based on the scope
and complexity of services to be provided and the estimated time required. Fees are
discussed and agreed upon in advance of engagement. Payment is remitted by check or
through PayPal, as agreed with the client.

Subscription Service Fees

PPS offers a weekly podcast, The Mid-Week Reality Check, which is provided for
informational and entertainment purposes. The annual subscription fee is $50.00.
Payment may be made by check or through PayPal.

Real Time Reality Alerts

Real Time Reality Alert fees are billed quarterly in advance. Payment is due upon
invoicing and may be made by check or through PayPal, as agreed with the client.

Signal Investment Fees

Castleview Partners bills and collects advisory fees directly from participating clients on
a monthly basis, in arrears, based on the account value as of the last business day of the
month. Under the Signal Investing arrangement, Castleview pays PPS a fee equal to 0.50%
of assets under management allocated to the IDEC strategy. Compensation is remitted to
PPS monthly by check.

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 redemption fees, and the internal fees that mutual funds
       charge for management and administration and are disclosed in each mutual funds
       prospectus, transaction fees, etc.). Those fees are separate and distinct from the fees and
       expenses charged by PPS.

       Please see Item 12 of this brochure regarding broker/custodian.

       D. Prepayment of Fees

       PPS generally collects advisory fees in advance. In the event of termination, any unearned
       portion of fees paid in advance will be refunded on a prorated basis.
...

Item 7: Types of Clients

PPS generally provides investment advice to the following Types of Clients:

              Individuals
              High-Net-Worth Individuals
              Corporations
              Advisors

  Minimum Account Size

  There is a retail account minimum of $100,000, which may be waived by the investment
  advisor based on the needs of the client and the complexity of the situation. The firm will
  aggregate accounts originating from the same household for purposes of meeting this
  minimum. Clients are not required to maintain an account size, however if a client's
  account falls to a level they can no longer participate in the strategy they will be contacted
  that their account can no longer be actively traded.