Regatta Research & Money Management LLC

ITEM 5: Fees and Compensation
PORTFOLIO MANAGEMENT AND ASSET ALLOCATION SERVICES:

    (1) Regatta’s management fees are negotiable from the inception of and during the execution of the
        management agreement and are applied to all assets under management at Regatta, unless
        specifically excluded in a written agreement between Regatta and the client. Including active and
        passively managed vehicles, concentrated and alternative liquid and illiquid positions, in-house
        managed portfolios, and those outsourced to a third-party money manager.

    (2) Fees are due and payable in advance on the first day of the month that begins a new calendar
        quarter. Regatta deducts fees from Clients’ assets or directly bills Clients for fees incurred.
        Clients may select either method. The fees are either directly billed or more often deducted
        directly from Clients’ account(s) and a billing statement is sent to the owner of the account on a
        quarterly basis. Annual fees range from 1/4% to 2% of the Client’s assets under management.
        One quarter (1/4) of the annual management fee is charged in advance for the upcoming quarter.
        Clients whose funds are submitted for management after the last day of the previous quarter but
        before the first day of the last month of the current quarter are billed on a pro-rata basis for the
        remaining days of the current quarter. Only additions over ten thousand dollars, whether in one
        deposit or multiple deposits, will be billed pro-rata. For additions that do not meet the de minimus
        exception, there will be no pro-rata charge.

    (3) Fees depend on a variety of factors including, but not limited to: the nature of the Client’s goals
        and circumstances, the amount of the Client’s assets managed by Regatta, the complexity of
        client’s accounts, changes in the Client’s risk profile, increased or decreased allocations towards
        fixed income or stocks and alternatives, number of accounts, increases or decreases in the Client’s
        non- discretionary activity, increases or decreases in the Client’s assets managed by Regatta, the
        amount of initial and ongoing work required by Regatta, Regatta's desire to strengthen and
        maintain the Client relationship, the introduction of new trading platforms or investments, etc.

    (4) At Regatta's sole discretion the money management fee may be reduced or waived for certain
        classes of Clients such as current or former employees, relatives, solicitors, Clients who are
        experiencing economic hardships, etc.

    (5) In addition to Regatta’s fees as set forth above, Clients utilizing the services of a third-party
        manager will separately incur the fees charged by the third party. If a third-party manager is
        utilized, this layering of fees will lower the Client’s overall return.

FINANCIAL PLANNING SERVICES:

Financial planning fees will be calculated based on a charge ranging from $200 to $300 per hour
depending on the nature and complexity of the individual Client’s needs. The length of time it will take to
create a financial plan will depend on each Client’s requirements. All fees are agreed upon prior to
entering a contract with any Client. Fees are due and payable upon completion of the plan. There is no
minimum financial planning fee.

If a financial planning services Client implements investment recommendations by engaging Regatta for
Portfolio Management Services, Regatta may, at its discretion, waive, discount, or adjust any financial
planning fees.

ADDITIONAL INFORMATION ON FEES AND EXPENSES:

For purposes of the following discussion, unless otherwise specified, the term “investment” includes
among other vehicles: mutual funds, exchange traded products, interval funds, stocks, bonds, certificates
of deposit, hedge funds, managed commodity pools, non-publicly traded REITs, limited partnerships,
private placements, annuity sub-accounts, structured products, fixed or variable annuities or other
investment products having unit values determined on a daily basis, quarterly basis, etc.

Investment vehicles such as mutual funds, interval funds, variable annuity sub-accounts, Separately
Managed accounts, Exchange Traded Fund products, Limited partnership interests, managed futures, hedge
funds, REIT companies, etc. charge a fee which is assessed as an expense on an ongoing basis and are paid
from Clients’ assets. Such fees include administrative fees, management fees, shareholder service fees and
certain other fees, etc., all of which reduce the net asset value of the shares of the investment vehicle
utilized.

Clients of Regatta who are invested in these vehicles are, in effect, paying an additional level of fees.
Clients pay a management fee to Regatta based on the market value of the Client’s assets under Regatta's
management and Clients indirectly or, in some cases, directly, pay additional fees and expenses to the
mutual fund, annuity company, ETF sponsor, REIT, separately managed accounts, hedge fund managers,
private equity, private real estate, etc., on the underlying investment as disclosed in the prospectus and
related disclosure documents. Furthermore, variable annuities charge additional expenses in the same
manner, including mortality and administrative charges. Additionally, custodians such as Fidelity, Equity
Institutional, Jefferson National, etc. may charge an annual maintenance fee depending on the account
type, size of the account, whether or not the account has systematic investing plan, whether it is a
conventional or alternative investment, etc. There are fees associated with TransAmerica RetireOne and
Advisor Elite variable annuities for insuring that the dollar value of the account used for annuitization
does not fall below a certain dollar level. With certain investments such as managed commodity pools,
...

ITEM 7: Types of Clients

Regatta manages assets for individuals, families, pension and profit-sharing plans, trusts, estates, charitable
organizations, corporations, and other business entities. Regatta may also manage assets as a Third-Party
Investment Advisor for other professionals such as Registered Representatives and RIAs. There are no
account minimums to open or maintain accounts.