Saiph Capital LLC

Item 5. Fees and Compensation
      Saiph Capital offers services on a fee basis, which includes fixed fees, as well as fees based upon assets
      under management. Additionally, certain of the Firm’s Supervised Persons, in their individual capacities,
      offer insurance products under a separate commission-based arrangement.

      Investment Management Fees

      Saiph Capital offers investment management services for an annual fee based on the amount of assets under
      the Firm’s management. This management fee varies between 75 and 125 basis points (0.75% – 1.25%),
      depending upon the size and composition of a client’s portfolio, the type and amount of services rendered
      and the individual(s) providing the services.

      The annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets on
      the last day of the previous quarter as determined by a party independent from the Firm (including the
      client’s custodian or another third-party). If assets are deposited into or withdrawn from an account after
      the inception of a billing period, the fee payable with respect to such assets is adjusted to reflect the interim
      change in portfolio value and refunded or added to the next bill. For the initial period of an engagement,
      the fee is calculated on a pro rata basis. In the event the advisory agreement is terminated, the fee for the
      final billing period is prorated through the effective date of the termination and the outstanding or unearned
      portion of the fee is charged or refunded to the client, as appropriate.

      The Firm includes cash in a client’s account in determining the valuation for billing purposes. The Firm
      may, in its sole discretion, not include cash in determining the fee, especially where a client has a high
      percentage of cash for reasons other than the Firm's investment management decision. Additionally, for
      asset management services the Firm provides with respect to certain client holdings (e.g., held-away assets,
      accommodation accounts, alternative investments, etc.), Saiph Capital can negotiate a fee rate that differs
      from the range set forth above. Clients are advised that a conflict of interest exists for the Firm to
      recommend that clients engage Saiph Capital for additional services for compensation, including rolling
      over retirement accounts or moving other assets to the Firm’s management. Clients retain absolute
      discretion over all decisions regarding engaging the Firm and are under no obligation to act upon any of the
      recommendations.

      Retirement Plan Consulting Fees
      Saiph Capital charges a fixed project-based fee to provide clients with retirement plan consulting services.
      Each engagement is individually negotiated and tailored to accommodate the needs of the individual plan
      sponsor, as memorialized in the Agreement. These fees vary, based on the scope of the services to be
      rendered, and range from $15,000 to $50,000 per annum on a fixed fee basis or up to 35 basis points (0.35%)
      per annum, depending upon services provided and the amount of assets to be advised on.

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 Disclosure Brochure

      Fee Discretion

      Saiph Capital may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such
      as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be
      managed, related accounts, account composition, pre-existing/legacy client relationship, account retention,
      pro bono activities, or competitive purposes.

      Additional Fees and Expenses

      In addition to the advisory fees paid to Saiph Capital, clients also incur certain charges imposed by other
      third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions
      (collectively “Financial Institutions”). These additional charges include securities brokerage commissions,
      transaction fees, custodial fees, margin and other borrowing costs, charges imposed directly by a mutual
      fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and
      other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
      electronic fund fees, fees charged by the Independent Managers, and other fees and taxes on brokerage
      accounts and securities transactions. The Firm’s brokerage practices are described at length in Item 12,
      below.

      Direct Fee Debit

      Clients provide Saiph Capital and/or certain Independent Managers with the authority to directly debit their
      accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified
      custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed
      to send statements to clients not less than quarterly detailing all account transactions, including any amounts
      paid to Saiph Capital. Alternatively, clients may elect to have Saiph Capital send a separate invoice for
      direct payment.

      Account Additions and Withdrawals

      Clients can make additions to and withdrawals from their account at any time, subject to Saiph Capital’s
      right to terminate an account. Additions can be in cash or securities provided that the Firm reserves the
      right to liquidate any transferred securities or declines to accept particular securities into a client’s account.
      Clients can withdraw account assets on notice to Saiph Capital, subject to the usual and customary securities
      settlement procedures. However, the Firm designs its portfolios as long-term investments and the
...

Item 7. Types of Clients
      Saiph Capital offers services to individuals, banking and thrift institutions, trusts, estates, charitable
      organizations, endowments, corporations and other business entities, pension and profit-sharing plans.