Turner Capital Investments LLC

Fees and Compensation - Item 5

 Strategy Management Fees
 For strategy management services, TCI charges a non-negotiable annual fee based on a percentage of assets
 under management.

 TCI charges the following annualized strategy management fees for household assets under management
 (AUM):

          TCI Strategies
          • 2.0% for household AUM (under $2.5 million).
          • 1.5% for household AUM ($2.5 million-up to $5 million)
          • 1.0% for household AUM ($5million and above).

 The fees and expenses in connection with these advisory services may be higher or lower than the cost of
 similar services offered through other financial firms, or the fees associated with other financial services.

 1/12th of the “annual management fee” is processed at the beginning of each calendar month for the upcoming
 month from each client account. TCI does not prorate management fees for partial months when accounts are
 opened. Likewise, TCI does not prorate management fees for the exit month in which the client discontinues to
 use TCI for account management.

 Sub-Advisory Services and Fees
 TCI receives fees as a sub-advisor of assets under advisement from RIAs. The fees are either paid directly to TCI
 by the sub-advisor, or TCI collects fees directly from the RIAs linked client accounts via Schwab Alliance as per
 the sub-advisory agreement.

 Promoter Services and Fees
 TCI engages promoters. Promoter fees are paid by TCI to the promoter per the promoter agreement.

 Additional Fees and Expenses
 TCI management fee is exclusive of, and in addition to, brokerage commissions, transaction fees, and other
 related costs and expenses. Clients are responsible for brokerage costs incurred. However, TCI will not receive
 any portion of the commissions, fees, and costs. Please see Item 12 – Brokerage Practices for further information
 on brokerage arrangements.

 Billing on Cash Positions: The firm treats cash and cash equivalents as an asset class. Accordingly, unless
 otherwise agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included
 as part of assets under management for purposes of calculating the firm’s advisory fee. At any specific point in
 time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such
 anticipated market conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for
 defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts
 could miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could
 exceed the interest paid by the client’s cash or cash equivalent positions.

 Periods of Strategy Inactivity: The firm has a fiduciary duty to provide services consistent with the client’s best
 interest. As part of its investment advisory services, the firm will review client account strategies on an ongoing
 basis to determine if any changes are necessary based upon various factors, including but not limited to
 investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial

Turner Capital Investments, LLC
Form ADV Part 2A

 circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may
 be extended periods of time when the firm determines that changes to a client’s account strategy are neither
 necessary nor prudent. Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment
 advisory fee will continue to apply during these periods, and there can be no assurance that investment decisions
 made by the firm will be profitable or equal any specific performance level(s).

 All fees paid to TCI for investment advisory services are separate and distinct from the fees and expenses charged
 to shareholders by exchange traded funds. These fees and expenses are described in each fund's prospectus.
 These fees generally include a management fee, other fund expenses, and a possible distribution fee. If the fund
 also imposes sales charges, you may pay an initial or deferred sales charge. A client could invest in such funds
 directly, without the services of TCI. In which case, the client would not receive the services provided by TCI, which
 are designed, among other things, to assist the client in determining which fund or funds are most appropriate to
 their financial condition and objectives. Accordingly, clients should review the fees charged by the funds and the
 fees charged by TCI to fully understand the total amount of fees charged and to evaluate the cost of advisory
 services being provided.

                         Performance-Based Fees and Side-By-Side Management - Item 6

 TCI does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation
 of the assets of a client). TCI is compensated from the fees based on assets under management.

Types of Clients – Item 7

 TCI intends to provide advice and services to affluent individuals, and corporations and other business entities. A
 minimum of $250,000 of assets under management is generally required to open a relationship with TCI. The
 minimum investment amount may be negotiable under certain circumstances, including the total relationship
 with TCI and the size of the account(s).

                       Methods of Analysis, Investment Strategies and Risk of Loss - Item 8

 TCI's investment strategies are very actively managed and market directional. TCI may change investment strategy
 based on market trends. TCI uses the following approach to trading and managing client portfolios:

     •    Trading decisions and investments (including, but may not be limited to, equities, exchange traded funds,
          cash, and cash equivalents) held in client accounts are at the complete discretion of the strategy manager
          but, in general, follow the profile and objectives of the TCI strategy that the client has selected to follow.

 Turner Capital Strategy Overviews
 Below is a list of strategies that TCI manages on behalf of individual clients. Each strategy is distinctly unique. All
 clients, except for special situations more typically found in high-net-worth client accounts, follow one or more
 of these strategies.

 TMI (Total Market Index) Strategies

Turner Capital Investments, LLC
Form ADV Part 2A

 TMI-1x and TE-1x: Has the objective to grow capital via the technical trading of a 50/50 investment in the 1x
 (non-leveraged) index tickers SPY and QQQ in bullish trends and the 1x (non-leveraged) index tickers SH and
 PSQ in bearish trends.

 TMI-1x/CASH: Has the objective to grow capital via the technical trading of a 50/50 investment in the 1x (non-
 leveraged) index tickers SPY and QQQ in bullish trends and does not go short. Will hold a 100% cash position in
 bearish trends.

 TMI-2x and TE-2x: Has the objective to grow capital via the technical trading of a 50/50 investment in the
 2x (leveraged) index tickers SSO and QLD in bullish trends and the 2x (leveraged) index tickers SDS and QID in
 bearish trends.

 TMI-2x-ON: Has the objective to grow capital via the technical trading of a 100% investment in the 2x (ultra-
 leveraged) indexes of the Nasdaq using the QLD ETF in bullish trends and QID the 2x (ultra-leveraged) in bearish
 trends.

 TMI-2x/CASH: Has the objective to grow capital via the technical trading of a 50/50 investment in the 2x
 (leveraged) index tickers SSO and QLD in bullish trends and does not go short. Will hold a 100% cash position in
 bearish trends.

 TMI-3x and TE-3x: Has the objective to grow capital via the technical trading of a 50/50 mix of the 3x (ultra-
 leveraged) indexes of the S&P 500 and Nasdaq using the UPRO ETF and the TQQQ ETF in bullish trends and the
 3x (ultra-leveraged) inverse SPXU ETF and inverse SQQQ ETF in bearish trends.

 TMI-3x-ON: Has the objective to grow capital via the technical trading of a 100% investment in the 3x (ultra-
 leveraged) indexes of the Nasdaq using the TQQQ ETF in bullish trends and SQQQ the 3x (ultra-leveraged) in
 bearish trends.

 TMI-3x/CASH: Has the objective to grow capital via the technical trading of a 50/50 investment in the 3x
 (leveraged) index tickers TQQQ and SQQQ in bullish trends and does not go short. Will hold 100% cash position
 in bearish trends.

 CASH Only: holds cash, or high yielding money markets.

 Clients should keep in mind that depending on when the client’s account was funded and TCI began investing the
 capital, the client’s account(s) results may vary from other TCI clients who are in the same mode solely due to the
 basis in holdings that are time-sensitive to the time opening trades were made.

 A client should not place his/her funds into a TCI managed account unless the client understands the extent of
 the strategy selected by the client to follow and its associated potential exposure to risk. Trading in the stock
 market is not suitable for all investors. Clients should carefully consider whether trading in the stock market is
 appropriate in light of the client’s experience, objectives, financial resources and other relevant circumstances.
 Generally, the strategy used by TCI are not appropriate for someone of limited resources and limited investment
 or trading experience and low risk tolerance.

Turner Capital Investments, LLC
Form ADV Part 2A

 Risk of Loss
 There are always risks to investing. Clients should be aware that all investments carry various types of risk,
 including the potential loss of principal that clients should be prepared to bear. It is impossible to name all possible
 types of risks. Among the risks are the following:

 Political Risks. Most investments have a global component, even domestic stocks. Political events anywhere in
 the world may have unforeseen consequences to markets around the world.

 General Market Risks. Markets can, as a whole, go up or down on various news releases or for no understandable
 reason at all. This sometimes means that the price of specific securities could go up or down without real reason
 and may take some time to recover any lost value. Adding additional securities does not help to minimize this
 risk since all securities may be affected by market fluctuations.

 Strategy Risk. When investments are made through a strategy, rather than individualized investment
 considerations, there is always the possibility that individualized investment choices would have produced a more
 positive result for a client than an approach where investments are made for a group of individuals with common
 characteristics.

 Tax Risks Related to Short Term Trading. Clients should note that TCI may engage in short-term trading
 transactions. These transactions may result in short term gains or losses for federal and state tax purposes, which
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