Syntax Research Inc

Item 5. Fees and Compensation
     Generally, Syntax’s fees are negotiable and may vary based on the circumstances of each client.
     Syntax generally charges clients an annualized fee based on the amount of assets under management
     subject to [in certain instances} a minimum fee amount.

     Each client fee schedule is negotiated, on a client-by-client basis. Client facts, circumstances and needs
     determine the fee schedule. These include the complexity of the client's account, assets to be placed
     under management, portfolio style, reports and other factors. The specific annual fee schedule will be
     identified in the contract between the adviser and each client. Pre-existing advisory clients are subject
     to our minimum account requirements and advisory fees in effect at the time such client enters the
     advisory relationship.

     MODEL PORTFOLIO DESIGN AND MANAGEMENT
     This service is predominantly for the benefit of other advisors or financial institutions, utilizing our model
     strategies. Our annual fee for this service is charged based on the amount of assets invested per the
     model portfolio(s), at an annual rate of 0.25% to 0.50% of assets in the accounts.

     PORTFOLIO MANAGEMENT
     This service is predominantly for the benefit of clients with specific or unique portfolio needs, including
     customized portfolios. Our annual fee for this service is charged based on the amount of assets under
     management, at an annual rate of 0.50% to 1.00%. In certain situations, Syntax may charge a flat
     fee instead of the typical percentage of assets under management.

     Syntax has two billing and payment structures. This will be set forth in each client’s advisory agreement.

     A client can be invoiced quarterly in advance for the balance of the estimated advisory fee for the first
     calendar quarter of the engagement, beginning in the second calendar quarter. For all subsequent years,
     a client will also be invoiced quarterly in advance at the beginning of each calendar quarter based upon
     the value (market value or fair market value in the absence of market value) of the applicable assets at
     the end of the previous quarter.

     A client may instead be invoiced or have its account with its custodian directly debited, as authorized in
     the client’s advisory agreement. A client may also instruct its custodian to debit its account for advisory
     fees. In such event, the custodian will make all calculations, based on the advisory contract and Syntax
     will not calculate the fee, nor send a bill to the custodian. Syntax will not directly debit any client account
     without receiving such client’s written authorization. Advance payment will never exceed $1,200

Syntax Research, Inc. 150 East Palmetto Park Road, Suite #800 Boca Raton, FL 33432                Tel: (561) 400 4940

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     for work that will not be completed within six months.

     FEES CHARGED BY FINANCIAL INSTITUTIONS

     All fees paid to Syntax for investment advisory services are separate and distinct from the fees and
     expenses charged by mutual funds, ETFs, variable life sub-accounts, and variable annuity sub- accounts
     (collectively, the "Funds") to their shareholders. These fees and expenses are described in each Fund's
     prospectus. These fees will generally include a management fee, other fund expenses, and a possible
     distribution fee. If the Fund also imposes sales charges, a client may pay an initial or deferred sales
     charge. Syntax does not, however, receive any portion of these commissions, costs or related costs.

     A client could invest in a Fund directly, without our services. In that case, it would not receive the services
     provided by Syntax which are designed, among other things, to assist the client in determining which
     Fund or Funds is most appropriate to such client’s financial condition and objectives. Accordingly, a
     client should review both the fees charged by the Funds and the fees charged by Syntax to fully
     understand the total amount of fees to be paid by it and to thereby evaluate the advisory services being
     provided.

     In addition, each client is responsible for the fees and expenses charged by custodians, broker dealers,
     and insurance companies. See Item 12 — "Brokerage Practices," and Item 15 — "Custody." Such fees
     may include, but are not limited to, any transaction charges, fees for duplicate statements and
     transaction confirmations, and fees for electronic data feeds and reports.

     A client agreement may be cancelled at any time, by either party, for any reason upon receipt of
     30 days written notice. Syntax may reserve the right to terminate an agreement if the value of the
     account falls below a predetermined amount, as set forth in the agreement with us. Upon termination
     of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will
     be due and payable. Clients may make a request for a refund in such termination notice. Refunds will
     be determined pro rata based on the number of days remaining in the quarter in which the client
     agreement is terminated. The client has the right to terminate an agreement without penalty within five
     business days after entering into theagreement.

Item 7. Types of Clients

     Syntax provides advisory services to individuals, their related trusts and estates and investment advisers,
     charitable institutions, other advisors, broker dealers and other financial services providers.
     Generally, Syntax requires a minimum account size to open an account, depending on the type of service
     to be provided, as described below. This is subject to negotiation and may vary based on the particular
     circumstances of each client. Syntax may accept lower account sizes in its discretion. In addition, certain
     affiliated persons and family members and personal acquaintances of affiliated persons may receive
     advisory services at smaller account sizes. Generally, Syntax has the following requirements:

Syntax Research, Inc. 150 East Palmetto Park Road, Suite #800 Boca Raton, FL 33432                Tel: (561) 400 4940

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     MODEL PORTFOLIO DESIGN AND MANAGEMENT
     Minimum account size:          Dependent on relationships with counterparties

     PORTFOLIO MANAGEMENT
     Minimum account size:                     $1,000,000

     Syntax reserves the right to accept accounts on an individual basis.