PVG Asset Management Corp

Item 5. Fees and Compensation

     A. PVG typically charges a base management fee of 2% which is frequently
        negotiated lower, depending upon client circumstances, account size, and
        source, such as those from financial advisors and broker dealers where PVG
        may act as a sub-advisor. Fees can vary greatly depending on the individual
        client. PVG generally bills fees quarterly in advance directly to a client’s
        account or to the client, depending upon client instructions. PVG may also bill in
        arrears for some platforms or direct accounts. This is all negotiated upfront with
        direct clients or third-party/sub-advised clients. Clients will have signed
        permission for the withdrawal of fees with both PVG and the custodian.
        Exceptions include those where PVG acts as a sub-advisor. Fees can vary
        greatly depending on the individual client.
     B. Besides management fees, clients may incur charges from their selected
        broker/custodian such as custodial fees, trading commissions and internal fund
        charges. Additionally, for restricted securities PVG may charge an account
        setup fee. These charges may be negotiated by PVG, the client, or may be set
        by the financial advisor or broker/dealer introducing a client to PVG. PVG does
        not share in any of these fees or charges.
     C. Unearned fees, if a client terminates PVG before any billed fees are earned, fees
        are refunded upon the request of the client. Client fees will be refunded in the case
        of termination, based on the formula stated on their contract, and the amount
        refunded is based upon the number of days remaining in a billing period
        divided by the total days in that billing period. PVG or the client may terminate
        the investment advisory contract at any time by giving written or electronic
        notice but needs to be confirmed by PVG.
     D. For clients that utilize the firm’s financial planning services, the monthly fee will
        be in a separate agreement defining the fee, and timing of the payment of the
        fee.

Item 7. Types of Clients

PVG manages accounts for other investment advisors, broker dealer platforms, hedge
funds, fund of funds, corporations, family offices, individuals, corporate and individual
retirement plans, foundations and endowments. Minimum account sizes vary greatly
based on individual client considerations and the source of each prospective client. To
be a client and included as assets that PVG is providing investment advisory services
PVG may not have authority to execute trades directly, but clients need to provide
sufficient information to make timely decisions.