Private Harbour Investment Management & Counsel LLC

Item 5 - Fees and Compensation

Private Harbour provides investment management and counsel to investors in exchange
for a fee.

Fee schedules for individually managed portfolios are as follows:

Balanced Fee Schedule:
Annual fee of 1.0% on the first $1 million
0.75% on the next $4 million
0.6% on the next $5 million
0.5% on the amount over $10 million

Equity Only Fee Schedule:
Annual fee of 1.0% on the first $5 million
0.8% on the next $5 million
0.6% on the amount over $10 million

Fixed Income Fee Schedule:
Annual fee of 0.6% on the first $1 million
0.5% on the next $1 million
0.4% on the next $3 million
0.3% on the amount over $5 million

Managed 401(K) Fee Schedule:
Annual Fee of 0.65%

Private Harbour offers a 20% reduction from our regular fee schedules to charitable
organizations.

Private Harbour reserves the right, in its sole discretion, to negotiate and to charge
different advisory fees for certain accounts based on the client's particular needs as well as
overall financial condition, goals, risk tolerance, and other factors unique to the client's
relationship with the firm. Fees charged to large account clients may be subject to
negotiation because of the initial or potential size of the accounts. Differences in advisory
fees paid by certain clients may also reflect different account inception dates, or the
entirety of the client's relationship with the firm. Private Harbour may, under appropriate
circumstances, make special fee arrangements with clients and may also elect to exclude
from billed assets certain low-cost basis securities in taxable accounts because of large
built-in capital gains that new clients bring to the firm at the start of the relationship.

Private Harbour may also provide investment advice on a non-discretionary basis
through consultation in selected cases where the client wishes to benefit from the firm's
investment knowledge and experience but is not able to grant discretionary investment
powers to the firm. The client's portfolio will be reviewed on a mutually agreed-upon
basis and specific new investment opportunities will be brought up for consideration.
Fees for such consultation are negotiable.

As a convenience to our client’s, Private Harbour's clients typically authorize their account
custodian to debit one or more of their accounts for Private Harbour's investment advisory
fee and to directly remit that management fee to Private Harbour. We strive to do this in a
tax-efficient manner, depending on clients’ personal account situation. Clients may also
choose to be billed for fees incurred, instead of deducting fees from their assets under
management. Private Harbour invoices clients in advance, at the beginning of each
quarter, based on the value of the funds, securities and other assets under management at
the end of the last business day preceding the billing date.

In conjunction with our making asset allocation investment decisions, some clients request
(and/or we occasionally recommend) that we perform a financial planning exercise to
gauge whether clients have enough assets to live the way they wish in retirement, given a
variety of assumptions about investment rates of return, tax rates, client income, tax
deductions, etc. In cases where we perform such a review, we may charge an hourly fee
for the time we need to review clients’ financial, tax and estate planning materials.

Once complete, we will make recommendations to improve their overall financial situation
where warranted. These reviews, the documents that are created because of this process,
are what constitute our financial planning process. Our only compensation is derived
from the amount of time we spend working on the client's situation. We do not sell
annuities or insurance. We do not offer fee-based subscriptions. Fees charged range from
$1,000 for a basic review to more than $5,000 for a more complex review. Fees are
negotiable and may be offset partially or entirely in conjunction with long-term
investment management relationships of sufficient size. For financial planning clients,
compensation is payable after the review has been completed. We do not offer refunds for
this type of work. There are no investments to "terminate" regarding a financial plan that
we have prepared.

In addition to Private Harbour's investment management fee, clients may incur custodian
fees and brokerage fees. In some cases, custodian fees are included in the brokerage fees.
Since our fees are charged on an "Assets Under Management" basis, it is in both our
clients' interest as well as our own to strive to limit client expenses. Therefore, on behalf
of our clients, we have negotiated commission and custodial fee rates down to what we
consider to be nominal levels to help save our clients’ money and improve their after-fee
returns.

Private Harbour may decide from time to time to put a portion of clients' assets into
exchange-traded funds, open-ended mutual funds or closed-end mutual funds to
achieve a certain investment result. When using any of the funds mentioned, clients
should be aware they are paying two levels of advisory fees for the management of
those assets. One fee is paid directly to Private Harbour and the other indirectly.
through the management fees assessed by the funds contained in their portfolio. Private
Harbour does not receive any portion of fees paid for the management of such securities.
Clients may also incur brokerage and other transaction costs. For additional information,
please see "Item 12: Brokerage Practices" later in this document.

Our clients are invoiced just after the beginning of the upcoming quarter. Therefore, some
part of our fee is billed in arrears, while most is billed in advance. For example, for the
quarter running from January 1 to March 31, most of our invoices are generally prepared
between January 12th and January 28th. The part before the invoice date is billed in
...

Item 7 - Types of Clients

Private Harbour generally provides investment advice to high-net-worth individuals,
pension/profit sharing plans, trusts/estates/charitable organizations, and corporations.

We generally require a minimum investment of $500,000 for a client to be separately
managed. Our minimum investment is negotiable, and we reserve the right to decline
business at our discretion.