Sulzberger Capital Advisors Inc

Item 5 Fees and Compensation
A. Fees
FEE SCHEDULE. Generally, the Firm charges an annualized advisory fee for assets under
management in accordance with the following schedule:

Managed Assets                             Annualized Fee
Up to $1,000,000                               1.00%
From $1,000,000 and up to $5,000,000
                                                 0.90%
Above $5,000,000                                 0.85%

Fees are based on the assets under the management of Sulzberger Capital for the particular account.
Fees will be charged monthly and in arrears. The monthly fee is based upon the market value of all
assets held within the client's account on the last business day of the calendar month. Lower advisory
fees may be negotiated on an individual account basis. As a result, clients with similar assets may
have differing fee schedules and pay different fees. The advisory services commence on the date on
which the advisory agreement is signed by us and the advisory account is funded. For the first
calendar month, fees may be adjusted pro rata based on the number of calendar days for which the
advisory agreement was in effect. Any contributions and/or withdrawals made during a month may
result in an adjustment to the advisory fee.

Since we bill in arrears, we will not charge any fees in excess of $1,200 more than six months in
advance.

The client may be charged a pro rata fee in the event the client's service is terminated on a day other
than the last business day of the calendar quarter. In that event, the pro rata fee will be due and
payable upon termination of the service.

HOW FEES ARE COLLECTED. The client's account will be debited for the above-mentioned fees. We
collect the fees from the amount of any contribution or transfer, from available cash in the client's
account, or by liquidating the client's assets held in the client's account in an amount equal to the fees
that are due.

FEE SCHEDULE MODIFICATIONS. We may adjust the fee schedule upon thirty (30) days' prior
written notice to the client.
LOWER FEE DISCLOSURE. Lower fees for comparable management services may be available from
other sources.

B. Termination of Service
Upon written notice to Sulzberger Capital, within five (5) business days of entering into an agreement
with the Firm, the client will have the right of termination without penalty or payment of fees. The Firm
will refund any payment that has been made. Thereafter, either Sulzberger Capital or the client may
terminate the agreement upon thirty (30) days' written notice to the other party. The Firm may
terminate access to the RightCapital client portal at any time and without notice to the client.

C. Other Fees
In addition to the advisory fees charged by the Firm, other fees may apply. Brokerage commissions,
transaction fees, sales loads, sales charges, management fees, administrative fees, account
maintenance fees, transfer taxes, wire transfer fees, electronic fund fees, and other fees may be
charged by the broker or dealer selected for execution of the securities transactions in the advisory
accounts, by the custodian, and/or by the distributor, issuer or fund issuing the securities purchased
and sold within the advisory accounts. The client is solely responsible for paying all such charges. In
addition, mutual funds and certain exchange-traded funds ("ETFs") pay management fees to their
investment advisers, which reduce their respective assets. To the extent that the client's portfolio has
investments in mutual funds or ETFs, the client may pay two levels of advisory fees for the
management of their assets: one directly to the Firm, and the other indirectly to the managers of those
mutual funds and ETFs held in their portfolios. Neither Sulzberger Capital nor any of its investment
adviser representatives receives any portion of these other fees.

D. Broker/Dealer Charges
Item 12 further describes the factors that Sulzberger Capital considers in selecting or recommending
broker/dealers for client transactions and determining the reasonableness of their compensation (e.g.,
commissions).

E. Margin Accounts/Margin Loans
We may trade client accounts on margin. Each client must sign a margin agreement before margin is
extended to that client account. Fees for advice and execution on these securities are based on the
total asset value of the account, which includes the value of the securities purchased on margin. While
a negative amount may show on a client's statement for the margined security as the result of a lower
net market value, the amount of the fee is based on the absolute market value. This creates a conflict
of interest where we have an incentive to encourage the use of margin to create a higher market value
and therefore receive a higher fee. The use of margin may also result in interest charges in addition to
all other fees and expenses associated with the security involved. It should be noted that the Margin
Agreement that a client will enter into is executed between the client and the broker-dealer/custodian.
Sulzberger Capital Advisors, Inc. is not a party to that Margin Agreement and receives no part of the
interest paid to the broker-dealer/custodian.

In limited cases, we may sell stock options for risk mitigation, hedging and incremental income
(covered calls). When a client sells (or 'writes') an option, it will show up on the Pershing statement as
a negative value. This is not dissimilar to trading on margin, as it is essentially temporarily borrowed
funds. For the purposes of fee statements, these negative values are excluded (i.e., added back) in the
same way as margin loans to derive the total asset value. This also shows up on the NetX portal on a
daily basis as the 'long market value'.

By way of example, a client holding 100 shares of a stock may decide to protect against significant
changes in asset value for a period of time and therefore sell 1 call contract for 100 shares (i.e., writes
...

Item 7 Types of Clients
Generally, we offer advisory services to individuals, trusts, estates, and organizations, corporations or
other business entities.

When subscribing to the advisory services offered by us, generally, the minimum account value is
US$100,000. If the value of a client's account declines below minimum amount during the advisory
relationship, we reserve the right to require the client to deposit additional monies or securities to bring
the account value up to the minimum. In some special cases, account minimums may be waived or
negotiated.