Tortuga Advisers LLC

Fees and Compensation
   Description
      TORTUGA ADVISERS LLC bases its fees on a percentage of assets under
      management, but that calculation is importantly influenced by the complexity
      of the assignment. Fees are individually negotiable.

                              TORTUGA ADVISERS LLC

   Fee Billing
       Investment management fees are billed quarterly, in advance, meaning that
       we invoice you before the billing period has begun. Payment in full is
       expected upon invoice presentation. 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.

   Other Fees
       Custodians may charge transaction fees on purchases or sales of certain
       mutual funds and exchange-traded funds. These transaction charges are
       usually small and incidental to the purchase or sale of a security. The
       selection of the security is more important than the nominal fee that the
       custodian charges to buy or sell the security.
       Mutual funds generally charge fees for their services and those fees are in
       addition to the fees charged by the firm.
       TORTUGA ADVISERS LLC, in its sole discretion, may waive its minimum fee
       and/or charge a lesser investment advisory fee based upon certain criteria
       (e.g., historical relationship, type of assets, anticipated future earning
       capacity, anticipated future additional assets, dollar amounts of assets to be
       managed, related accounts, account composition, negotiations with clients,
       etc.).

Types of Clients
   Description
      TORTUGA ADVISERS LLC generally provides investment advise to
      individuals, trusts, estates, charitable organizations and pension and profit
      sharing plans of small businesses.
       Client relationships vary in scope and length of service.

                              TORTUGA ADVISERS LLC

   Account Minimums
      The minimum account size is $1,000,000 of assets under management,
      which typically equates to an annual fee of $$7,500.
       TORTUGA ADVISERS LLC has the discretion to waive the account minimum.
       Such waivers are typically made for relatives or other referrals from current
       clients. We consider it important to work with nice people who want and need
       our help and are willing to consider waiving minimum fees under those
       circumstances.
       Clients with assets below the minimum account size may pay a higher
       percentage rate on their annual fees than the fees paid by clients with greater
       assets under management.

Methods of Analysis, Investment Strategies and Risk of Loss