Suncoast Capital Management

Item 5: Fees and Compensation

I A. Fee Schedule

Pension Consulting Services Fees

The rate for creating client pension consulting plans is commiserate with the detailed
scope of work. The final fee schedule will be memorialized in the client's
consulting contract or agreement. This service may be canceled with 30 days' notice.

Wealth Portfolio Management Fees

        Total Assets Under Mana2ement              Annual Fees
        $0 - $249,999                              3.00%

        $250,000 - $999,999                        2.00%

        $1,000,000 - AND UP                        1.00%

 SunCap uses the value of the account as of the last business day of the billing period, after
tak ing into account deposits and withdrawals, 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. Clients may terminate the agreement without penalty
for a full refund of SunCap's fees within five business days of signing the Investment
Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract
generally with 30 days' written notice.

Financial Planning Fees

Fixed Fees

The negotiated fixed rate for creating client financial plans is between $2,500 and
$50,000, commiserate with the detail and complexity of the plan.

Hourly Fees

The hourly fee for these services is $300.

Clients may terminate the agreement without penalty, for full refund of SunCap·s fees,
within five business days of signing the Financial Planning Agreement. Thereafter,
clients may terminate the Financial Planning Agreement generally upon written notice.

I 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Asset-based portfolio management fees are withdrawn directly from the client's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 quarterly basis, or may be invoiced and

          billed directly to the client on a quarterly basis. Clients may select the method in which
          they are billed. Fees are paid in advance.

          Payment of Pension Consulting Fees
          Fixed pension consulting fees are paid via account draft check or bank wires,
          based on invoicing. These fees are paid quarterly in arrears.

          Payment of Financial Planning Fees
          Financial planning fees are paid in arrears upon completion, via check or wire.

      I C. Client Responsibility for Third Party Fees

          This brochure describes SunCap·s non-wrap fee advisory services;
      [   D. Prepayment of Fees

          SunCap collects fees, some fees in arrears and some in advance. Refunds for fees paid in
          advance will be returned within fourteen days to the client via check, or return deposit
          back into the client's account.

          For all asset based fees paid in advance, the fee refunded will be equal to the balance of
          the fees collected in advance minus the daily rate* times the number of days elapsed in
          the billing period up to and including the day of termination. (*The daily rate is
          calculated by dividing the annual asset-based fee by 365.)

      I E. Outside Compensation for the Sale of Securities to Clients

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

Item 7: Types of Clients
SunCap generally provides advisory services to the following types of clients:

          ❖      Individuals
          ♦      High-Net-Worth Individuals
          ❖      Pension and Profit Sharing Plans
          ❖      Charitable Organizations

        ❖      State or Municipal Government Entities

There is no account minimum for SunCap·s services.