Richmond Capital Advisors LLC

Item 5: Fees and Compensation

A. Fee Schedule

Robo-Advisory Portfolio Management Services Fees

                                                            RCA uses the value of the account as of the last business day
 Managed Portfolio                     Annual Fees
                                                            of the billing period, after taking into account deposits and
                                                            withdrawals, for purposes of determining the market value of
 Income Portfolio                      0.80%
                                                            the assets upon which the advisory fee is based.

 High Income Portfolio                 0..90%               These fees are generally negotiable, and the final fee
                                                            schedule will be memorialized in the client’s advisory
 Income & Growth Portfolio             1.00%                agreement. Clients may terminate the agreement without
                                                            penalty for a full refund of RCA's fees within five business days
 Moderate Growth Portfolio             1.10%                of signing the Investment Advisory Contract. Thereafter, clients
                                                            may terminate the Investment Advisory Contract immediately
 Aggressive Growth Portfolio           1.20%                upon written notice.

 Multisector Equity Portfolio          1.20%

Payment of Robo-Advisory Portfolio Management Fees
Robo-advisory portfolio management fees are withdrawn directly from the client's accounts with client's written
authorization on a monthly basis. Fees are paid in arrears.

B. Client Responsibility For Third Party Fees
Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees,
transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by RCA. Please see
Item 12 of this brochure regarding broker-dealer/custodian.

C. Prepayment of Fees
RCA collects its fees in arrears. It does not collect fees in advance.

D. Outside Compensation For the Sale of Securities to Clients
Daniel Jorge Richmond in his outside business activities (see Item 10 below) is licensed to accept compensation for the
sale of investment products to RCA clients. Per Rule 203A-2(e) Internet investment advisers are defined as advisers
that provide investment advice to all of its clients exclusively through an interactive website, except that the investment
adviser may provide investment advice to fewer than 15 clients through other means during the preceding twelve
months. Therefore, Daniel Jorge Richmond will not offer clients any services in his outside business capacity.

Item 7: Types of Clients

RCA generally provides advisory services to the following types of clients:

    •   Individuals
    •   High-Net-Worth Individuals

There is an account minimum of $100,000, which may be waived by RCA in its discretion.