Safe Harbor Asset Management Inc

Item 5: Fees & Compensation

    Compensation for Our Advisory Services

    Portfolio Management Service:

                                           Quarterly Percentage of         Annual Percentage of Assets
         Assets Under Management
                                               Assets Charge                        Charge
               First $250,000                      0.625%                            2.50%
         Next $250,001 to $500,000                 0.25%                             1.00%
        Next $500,001 to $2,000,000                0.20%                             0.80%
       Next $2,000,001 to $5,000,000               0.15%                             0.60%
              Over $5,000,001                    Negotiable                        Negotiable

    Fees to be assessed will be outlined in the advisory agreement to be signed by the Client. Annualized
    fees are billed on a pro-rata basis quarterly in advance based on the value of the account(s) assets on
    the date it is deducted. The value of the assets will be the market value reported by the custodian
    maintaining the client’s assets, and if there is no reported value for an asset, then the value of such
    asset will be the fair value as determined by our firm. Fees are negotiable and will be deducted from
    client account(s). Our firm bills on cash balances unless otherwise indicated in writing. Adjustments
    will be made for deposits and withdrawals during the quarter. In rare cases, our firm will agree to
    directly invoice. For new accounts, the initial advisory fee will be based upon the value of the client’s

ADV Part 2A – Firm Brochure                        Page 6                            Safe Harbor Asset Management, Inc.

    assets and will be prorated from the date the account is fully funded and will be due and payable at
    such time. Subsequent quarterly fees will be deducted from the client’s account. Please see Item 12
    of this Brochure for more information on our brokerage practices. As part of this process, Clients
    understand the following:

         a) The client’s independent custodian sends statements at least quarterly showing the market
            values for each security included in the Assets and all account disbursements, including the
            amount of the advisory fees paid to our firm;
         b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our
            firm will send an invoice directly to the custodian; and
         c) If our firm sends a copy of our invoice to the client, legend urging the comparison of
            information provided in our statement with those from the qualified custodian will be
            included.

    Financial Planning & Consulting:

    Our firm charges on an hourly or flat fee basis for financial planning and consulting services. The total
    estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our
    engagement with the client. The maximum hourly fee to be charged will not exceed $275. Flat fees
    range from $1,500 to $5,000. Our firm requires a retainer of 50% of the ultimate financial planning
    or consulting fee at the time of signing. The remainder of the fee will be directly billed to the client
    and due within 30 days of a financial plan being delivered or consultation rendered. Typically, the
    financial plan will be presented to the client within 10 days of the contract date, provided that all
    information needed to prepare the financial plan has been promptly provided by the client. For 1031
    Exchange Consulting, our firm shall provide financial consultations in two phases. In Phase One,
    clients shall be charged a flat fee not to exceed $5,000 for the initial interview with the client as well
    as the research conducted and 1031 Exchange Plan proposed following an initial client meeting.
    Clients who engage in Phase Two, shall be charged a fee not to exceed 6% of the assets (debt and
    equity) of the completed 1031 Exchange Plan which has resulted from our firm’s due diligence and
    assistance with various administrative tasks. Our firm will not require a retainer exceeding $1,200
    when services cannot be rendered within 6 months.

    Retirement Plan Consulting:

    Our Retirement Plan Consulting services are billed a fee based on the percentage of Plan assets under
    management. The total estimated fee, as well as the ultimate fee charged, is based on the scope and
    complexity of our engagement with the client. Fees will not exceed 1.00%. The fee-paying
    arrangements will be determined on a case-by-case basis and will be detailed in the signed consulting
    agreement.

    Educational Seminars:

    Our firm shall not charge fees for educational seminars.

    Other Types of Fees & Expenses

    Clients will incur transaction charges for trades executed in their accounts. These transaction fees
    are separate from our firm’s advisory fees and will be disclosed by the chosen custodian. Charles
    Schwab & Co. Inc. (“Schwab”) does not charge transaction fees for U.S. listed equities and exchange
    traded funds.

ADV Part 2A – Firm Brochure                         Page 7                            Safe Harbor Asset Management, Inc.

    These fees will generally include a management fee, other fund expenses, and a possible distribution
    fee. Certain Funds also impose sales charges. A client could invest in a Fund directly, without the
    services of our firm. In that case, the client would not receive the services provided by our firm which
    are designed, among other things, to assist the client in determining which Fund or Funds are most
    appropriate to each client’s financial condition and objectives. Accordingly, the client should review
    both the fees charged by the funds and the fees charged by our firm to fully understand the total
...

Item 7: Types of Clients & Account Requirements

    Our firm has the following types of clients:
        Individuals
        High Net Worth Individuals;
        Pension and Profit Sharing Plans;

    Our requirements for opening and maintaining accounts or otherwise engaging us:
        Our firm requires a minimum account balance of $100,000 for our Portfolio Management
           service. Generally, this minimum account balance requirement is not negotiable and would
           be required throughout the course of the client’s relationship with our firm.
        Written financial plans are generally assessed a minimum fee of $1,500.
        In limited circumstances, these minimums may be negotiable based on the nature and scope
           of the client relationship.