Polero Ice Advisers

Item 5 - Fees and Compensation

     The Firm is compensated solely by its clients, in one or more of the following ways, depending on the services
     requested:
               1.         a retainer fee for account management and ongoing nancial assistance

               2.         an hourly rate of $325/hour

               3.         a pre-agreed fee for a comprehensive plan or a module of a nancial plan

     When a client requests account management or a nancial plan, prior to beginning work, an agreement is signed
     between the client and Polero ICE Advisers L.L.C., listing the services to be provided and the fee for those
     services. If a client prefers an hourly-fee arrangement, the fee is $325/hour, and the nal fee is calculated when
     the work is completed.

     Retainer Fee for Account Management and Ongoing Financial Advice:
     When the Adviser is hired to manage investment accounts and provide ongoing nancial advice, clients can
     choose the frequency of payments that work best for them (e.g. quarterly, biannually or annually).

     The xed fee is determined by the number of accounts the client would like managed, as well as the total size and
     complexity of the client’s situation. Annual fees typically range from $7,000 -$15,000 for individual clients and
     couples, and include nancial planning.

     Fees are paid by check, Venmo or Zelle, but are never deducted directly from a managed account.

     Clients who have signed a contract to work with the Adviser on a retainer basis, have the right to cancel the
     services at any time by providing the Adviser with 2 weeks notice. No additional fees will be incurred after the 2-
     week period has ended, and if the client had prepaid any fees, they will be refunded on a pro-rata basis. The
     refund will be calculated as follows:

           # of actual calendar days in prepaid period prior to cancellation + 14 days (the notice period)
          ---------------------------------------------------------------------------------------------------------------------------- X Prepaid Fee
                                                                   POLERO ICE ADVISERS, L. L. C.

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                                        # of actual calendar days in the full prepaid period

                    Charging a at fee for account management, rather than a percentage of the assets being managed, serves to
                    reduce potential con icts of interest that could arise if the Adviser is asked to recommend the best strategy for a

                    client’s overall assets. There are times when putting money toward other uses (e.g. funding a separate
                    emergency account, buying a longevity annuity, or paying off a mortgage) would make sense for a client, but
                    would also reduce the size of the investment accounts being managed. Since the Adviser’s compensation does
                    not directly depend on the amount of assets being managed, there isn’t an incentive to avoid recommendations
                    that would reduce that amount.

                    Hourly Services:
                    Clients may choose to pay an hourly fee for nancial-planning assistance. In that case, the hourly charge is $325.

                    Fee for Full or Partial Financial Plan:
                    The charge for a full nancial plan depends on its complexity and extensiveness, and typically ranges from
                    $2,750- $4,500. If a client is interested in only certain sections of a nancial plan, partial plans addressing the
                    speci c areas of concern are available for a fee that usually ranges from $1,500 to $2,500, depending on the
                    number of the areas requested.

                    After the initial meeting with a client, the Adviser prepares a draft Engagement Agreement and Disclosure
                    Statement, listing the services that would be provided and the proposed fee for the nancial analysis. If the client
                    agrees with the scope of the service and the fee, the signed Agreement is approved by the client prior to the
                    commencement of any work, and typically 50% of the agreed-upon fee is paid at that point.

                    Follow-up reviews of an analysis can be requested by a client in years after an original analysis has been
                    prepared. These reviews will take into account the changes in a client’s nancial picture, as well as the overall
                     nancial environment and possibly new tax or other legislation that impacts the client. The typical charge for such
                    follow-up work ranges from $2.000 to $2,500.

                    The fees discussed above are paid directly to Polero ICE Advisers for portfolio management and/or nancial
                    planning services. It should be noted that when mutual funds and exchange-traded funds are held in a client’s
                    account, the funds charge their own management fees, which are separate from and in addition to, the Firm's fee.
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Item 7 - Types of Clients

     The Firm mainly serves high-net-worth individuals. However, the Firm also works with individuals who request
      nancial guidance but have a lower amount of nancial resources.

     There is no minimum asset level required for having an account managed by the Firm.