Rachor Investment Advisory Services LLC

ITEM 5: FEES AND COMPENSATION

Diversified and Concentrated Strategy Fees

       Rachor establishes the specific manner in which we charge our fees in the
written investment advisory agreement signed with us prior to beginning our relationship
with the client. Rachor standard fee schedule for assets invested in the Diversified and
Concentrated Strategies is as follows:

             Assets Under Management                    Total Annual Fee
             On the first $2,500,000                          1.0000%
             On the next $2,500,000                            0.5000%
             On the next $2,500,000                            0.2500%
             On the next $2,500,000                            0.1250%
             On the next $2,500,000                            0.0625%
             On the next $2,500,000                            0.0313%
             On the next $2,500,000                            0.0157%
             On the next $2,500,000                            0.0079%
             On the next $2,500,000 and greater                0.0040%

       Our fees are billed, in advance, at the beginning of each calendar quarter, based
upon the value of the client's account, including cash and cash equivalents, at the close
of business on the last day of the calendar quarter, as reported in our portfolio
accounting software.

       If the investment advisory agreement is executed at any time other than the first
day of a calendar quarter, our fees will be pro-rated for the number of days on which the
agreement was in effect. Such pro-rata adjustments are not made when a client adds or
withdraws assets to or from their account.

        Clients generally authorize Rachor, in the investment advisory agreement, to bill
our fees to the custodian of his or her account and grants the custodian permission to
directly debit our fees from the account. If necessary, we may liquidate investments in
the client’s account to pay our fee.

        Rachor will provide notice for investment advisory fees to each client; the notice
will be in the form of an invoice. If the client provides us such authorization, we will
provide the custodian with the request for payment and the client will receive periodic
statements from the custodian showing each fee deduction from his or her account.

Advisory Services for Qualified Plans

       The 3(38) Manager determines its fee, and the fee arrangement will be agreed
upon in the tri-party investment advisory agreement between the responsible plan
fiduciary, the 3(38) Manager and Rachor. The 3(38) Manager utilizes both tiered and
breakpoint pricing models. In tiered pricing, specified rates are applied to assets within
each of the rate brackets and added together to make up the fee. In breakpoint pricing,

Part 2A of Form ADV                          4        Rachor Investment Advisory Services, LLC

once the highest asset bracket is reached, the rate assigned to that bracket is applied to
all assets.

      Management fees for qualified plans are billed quarterly, in advance. Rachor
charges a flat annual fee of 0.55%. Generally, the fee schedule for the 3(38) Manager
and the combined annual fee are as follows:

                                                  3(38) Manager Combined
                Assets Under Management            Annual Fee   Annual Fee
                On the first $1,000,000             0.20%          0.75%
                $1,000,001 to $5,000,000             0.15%         0.70%
                $5,000,001 to $10,000,000            0.08%         0.63%
                Over $10,000,000                     0.05%         0.60%

Additional Information

        We retain the discretion to negotiate alternative fees on a client-by-client basis.
The specific annual fee schedule is identified in the investment advisory agreement
between Rachor and each client. We may change our fees at any time, and we always
have the right to amend our fees. Any changes will become effective after we provide
the client with 30 days’ prior written notice unless the client terminates our agreement.

        We provide employees, some family members, and friends the same services for
a fee lower than those charged to clients that are not related to the firm. These fees are
not available to our general clients. However, our employees do not receive reduced
fees from the Private Money Managers or broker/custodians we recommend to our
clients.

        A client agreement may be terminated at any time, by either party, for any reason
upon receipt of written notice. Upon termination, Rachor will promptly refund the client a
pro-rata portion of the prepaid, unearned fees, calculated to the date of termination.
Except for any advisory fees due and owing upon termination, Rachor will not be
entitled to any additional termination charge or termination fee.

       Termination of our agreement shall not affect liabilities or obligations incurred or
arising from transactions initiated under our agreement prior to the termination date,
such as the purchase of investments by us for the client’s account. After the termination
date, Rachor will have no further duties or obligations to the client under our agreement.

        Our agreement will not terminate in the event of the client’s death, disability, or
incompetency. However, in the event of client’s death, disability or incompetency,
client’s executor, guardian, attorney-in-fact, or other authorized representative may
terminate our agreement by giving us written notice, with such termination being
effective upon our receipt of such notice.

Part 2A of Form ADV                           5         Rachor Investment Advisory Services, LLC

Additional Fees and Expenses

       In addition to Rachor’s investment advisory fees, clients will incur the following
additional charges imposed by broker-dealers/custodians, including, but not limited to,
...

Item 7: Types of Clients

     While we continue not to impose a minimum account size requirement, we increased our
recommended minimum household investable asset value to $250,000.