Roosevelt Capital Management LLC

Item 5: Fees and Compensation

A. Fee Schedule

Portfolio Management Fees

Annual Fees: Roosevelt Capital Management will not charge more than 1.00% of assets
under management, and this fee is negotiable at the discretion of RCM and dependent on
the mix of products utilized by the client.

RCM uses the average daily value of the account over of the billing period for purposes
of determining the market value of the assets upon which the advisory fee is based.

These fees are generally negotiable, and the final fee schedule will be memorialized in the
client’s advisory agreement. Any increase in fees shall be accompanied by an amendment
or the execution of a new contract, with signatures from both parties evidencing
acceptance of the new fees. Clients may terminate the agreement without penalty for a
full refund of RCM's fees within five business days of signing the Investment Advisory
Contract. Thereafter, clients may terminate the Investment Advisory Contract generally
with 7 days' written notice.

Assets Under Advisement Fees

Roosevelt Capital Management will charge an annual fee of not more than 25 basis points
of assets under advisement, calculated on the market value of the advised assets as of the
last business day of each month. Fees will be invoiced monthly in arrears and are payable
within 30 days.

B. Payment of Fees

Payment of Portfolio Management Fees

       Asset-based portfolio management fees are withdrawn directly from the client's accounts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.

       C. 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 RCM. Please see Item 12 of this brochure
       regarding broker-dealer/custodian.

       D. Prepayment of Fees

       RCM collects its fees in arrears. It does not collect fees in advance.

       E. Outside Compensation for the Sale of Securities to Clients

       Neither RCM nor its supervised persons accept any compensation for the sale of
       investment products, including asset-based sales charges or service fees from the sale of
       mutual funds.

Item 7: Types of Clients

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

       ❖      Individuals                             ❖       Family Offices
       ❖      High-Net-Worth Individuals              ❖       Foundations
       ❖      Insurance Companies                     ❖       Corporations
       ❖      Trusts / Estates                        ❖       Hedge Funds
       ❖      Charitable Organizations                ❖       Private Investment Companies
       ❖      Investment Companies                    ❖       Pension and Profit-Sharing Plans
       ❖      Government Entities

There is an account minimum of $1,000,000.00 for any of RCM’s services.