Torren Management LLC

Item 5           Fees and Compensation

   A.
                                      INVESTMENT MANAGEMENT
         Registrant provides investment advisory services on a discretionary fee-only basis.
         Registrant’s annual investment advisory fee ranges between 0.25 and 0.90%, based upon

    the value of assets under the Registrant’s management. The Registrant’s fee schedule is as
    follows:

              Assets under Management                          Annual Advisory Fee
              $0-$3,000,000                                        0.90%
              $3,000,000-$5,000,000                                0.80%
              $5,000,000-$10,000,000                               0.65%
              $10,000,000-$40,000,000                              0.45%
              $40,000,000-$70,000,000                              0.35%
              $70,000,000-$100,000,000                             0.30%
              $100,000,000-$200,000,000                            0.25%
              $200,000,000+                                        Negotiable

    Tiered-Blended Pricing Schedule: The actual fees charged to a client are a blending of the
    rates above. For example, a client with $25,000,000 of assets under management would
    pay 0.90% annually on the first $3,000,000, 0.80% on the next $2,000,000, 0.65% on the
    next $5,000,000 and 0.45% on the next $15,000,000. The resulting blended fee would be
    0.57%.

    Fee Dispersion. Registrant, in its discretion, may charge a lesser or higher investment
    advisory fee, charge a flat fee, waive applicable minimum asset or minimum fee levels,
    waive its fee entirely, or charge fee on a different interval, based upon certain criteria (i.e.,
    anticipated future earning capacity, anticipated future additional assets, dollar amount of
    assets to be managed, related accounts, account composition, complexity of the
    engagement, anticipated services to be rendered, grandfathered fee schedules, employees
    and family members, courtesy accounts, referrals from existing clients, competition,
    negotiations with client, etc.). As result of the above, similarly situated clients could pay
    different fees. In addition, similar advisory services may be available from other
    investment advisers for similar or lower fees.

                     FINANCIAL PLANNING AND CONSULTING SERVICES
    Registrant’s planning and consulting services are offered on a fixed fee basis. The
    Registrant’s planning and consulting fees are negotiable. The Registrant’s fee shall be
    based upon the level and scope of the service(s) required and the professional(s) rendering
    the service(s). The Registrant may also be engaged by a client to complete a project
    separate and apart from the Registrant’s core services, in these instances the Registrant’s
    planning and consulting fee shall generally range from a minimum of $10,000 annually or
    higher amounts based on a negotiated fixed fee or hourly basis.

B. Clients may elect to have the Registrant’s advisory fees deducted from their custodial
   account. Both Registrant’s Investment Advisory Agreement and the custodial/clearing
   agreement may authorize the custodian to debit the account for the amount of the
   Registrant's investment advisory fee and to directly remit that management fee to the
   Registrant in compliance with regulatory procedures. In the limited event that the
   Registrant bills the client directly, payment is due upon receipt of the Registrant’s invoice.

C. As discussed below, unless the client directs otherwise or an individual client’s
   circumstances require, the Registrant shall generally recommend that National Financial
   Services, LLC (“Fidelity”) or Charles Schwab & Co., Inc. (“Schwab”), serves as the
   broker-dealer/custodian for client investment management assets.

         Broker-dealers such as Fidelity and Schwab charge brokerage commissions, transaction,
         and/or other type fees for effecting certain types of securities transactions (i.e., including
         transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed
         income transactions, etc.). The types of securities for which transaction fees, commissions,
         and/or other type fees (as well as the amount of those fees) shall differ depending upon the
         broker-dealer/custodian. While certain custodians, including Fidelity and Schwab,
         generally (with the potential exception for large orders) do not currently charge fees on
         individual equity transactions (including ETFs), others do.

         There can be no assurance that Fidelity or Schwab will not change their transaction fee
         pricing in the future.

         Fidelity and Schwab may also assess fees to clients who elect to receive trade confirmations
         and account statements by regular mail rather than electronically.

         Clients will incur, in addition to Registrant’s investment management fee, brokerage
         commissions and/or transaction fees, and, relative to all mutual fund and exchange traded
         fund purchases, charges imposed at the fund level (e.g., management fees and other fund
         expenses)

   D. Registrant's annual investment advisory fees shall be prorated and paid quarterly, in
      advance, based upon the value of the client’s managed accounts on the last day of the
      previous quarter.

         The Registrant typically requires a minimum asset level of $3,000,000 for investment
         management services. However, the Registrant my at its discretion, may choose to accept
         investment management relationships that do not meet the firm’s stated minimum asset
         requirement based upon various circumstances.

         The Investment Advisory Agreement between the Registrant and the client will continue in
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Item 7           Types of Clients

         The Registrant’s clients shall generally include individuals, businesses, and charitable
         organizations.