The Harbor Group Inc

Item 5 – Fees and Compensation
   Description
       THG bases its fees on a percentage of assets under management, hourly
       charges, and fixed fees (not including subscription fees). Please refer to Item
       4 above for a complete description of the fees THG charges for its particular
       services.
       Some agreements may be priced based on the complexity of work, especially
       when asset management is not the most significant part of the relationship.
       Therefore, financial plans are typically priced according to the degree of
       complexity associated with the client’s situation.
       Fees are negotiable in limited circumstances as discussed in Item 4.

                                  The Harbor Group Inc.

   Fee Billing
       Investment advisory fees are billed quarterly in arrears. The fee schedule is
       based upon the average daily balance during the billing period. Fees are
       usually deducted from a designated client account to facilitate billing. The client
       must consent in advance to direct debiting of their investment account.
       Fees for financial plans are billed upon delivery of the financial plan.

   Transaction and Custodial Fees
       Broker-dealers charge transaction fees for executing certain securities
       transactions according to their fee schedule and they or their affiliated or
       unaffiliated custodians also impose additional charges for custodial services
       and other fees associated with maintaining the client’s account. Without limiting
       the foregoing, clients may also be required to pay certain charges and
       administrative fees related to their investment advisory accounts, including, but
       not limited to: transaction charges (including mark-ups and mark-downs); prime
       brokerage fees resulting from trades executed through or with a broker-dealer
       other than the designated broker-dealer/custodian; transfer taxes; transfer or
       wiring fees; odd lot differentials; exchange fees; interest charges; American
       Depositary Receipt agency processing fees; and any charges, taxes or other
       fees mandated by any federal, state or other applicable law or otherwise agreed
       to with regard to client accounts. THG does not receive any portion of these
       fees or commissions.

   Expense Ratios
       Mutual funds and ETFs generally impose a management fee for the fund
       manager’s services. The management fee plus other fund expenses are
       sometimes called an expense ratio. For example, an expense ratio of 0.50
       means the mutual fund company charges 0.5% for their services and fund
       expenses. THG does not receive any portion of these fees, which are in
       addition to the fees paid by you to THG.

   Past Due Accounts and Termination of Agreement
       THG reserves the right to stop work on any account that is more than 30 days
       overdue. In addition, THG reserves the right to terminate any financial planning
       engagement where a client has willfully concealed or has refused to provide
       pertinent information about financial situations when necessary and
       appropriate, in THG’s judgment, to providing proper financial advice.

Item 7 – Types of Clients
   Description
       THG generally provides investment advisory services to individuals, high net
       worth individuals, pension and profit sharing plans, trusts, estates, charitable
       organizations, and business entities. The majority of clients are individuals and
       high net worth individuals.
       Client relationships vary in scope and length of service.

   Account Minimums
       THG does not impose any mandatory requirements for opening or maintaining
       investment advisory accounts. However, THG imposes a minimum annual fee
       for investment management services. If a client maintains less than a
       $1,000,000 average daily balance of assets under THG’s management as of
       the end of a billing quarter, the $10,000 annual minimum fee would trigger and
       THG would apply a minimum quarterly fee of $2,500. Notwithstanding the
       above, in no event will any client be charged in excess of 3.00% for investment
       management services.