Valtrion Capital Management LLC

Item 5. Fees and Compensation
      VCM offers services on a fee basis, which includes fixed fees and fees based upon assets under management
      or advisement. Additionally, certain of the Firm’s Supervised Persons, in their individual capacities, offer
      insurance products under a separate commission-based arrangement.

      Financial Planning and Consulting Fees

      VCM charges an annual fixed fee for providing financial planning and consulting services under a stand-
      alone engagement. These fees are negotiable depending upon the scope and complexity of the services and
      the professional rendering the financial planning and/or the consulting services.

      VCM generally charges the flat fee for the plan upfront at the point of execution of a signed advisory
      contract with VCM. The services other than the plan are offered to the client for twelve months after the
      execution of the agreement. Fees will auto renew annually on the date that clients engage VCM for services.
      Clients will be offered the same included services and an updated financial plan. However, exact fee(s) and
      fee-paying arrangements will be outlined in the Advisory Agreement to be signed by the client.

      The fees for the financial planning and consulting services are as follows:

                     Our Core Categories                                          Annual Fee
       Solo Plan                                              Annual flat fee of $995
       Family Plan                                            Annual flat fee of $1,995
       Retirement Plan                                        Annual flat fee of $4,495
       Executive Plan                                         Annual flat fee of $4,995
       Entrepreneur Elite Plan                                Annual flat fee of $9,995

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 Disclosure Brochure

      Investment Management Fees

      VCM offers investment management services for an annual fee based on the amount of assets under the
      Firm’s management. This management fee varies depending upon the type and amount of services rendered
      and the size and composition of a client’s portfolio. Unless otherwise noted, the annualized fee will be
      billed on a pro-rata basis monthly in arrears based on the value of the account(s) on the last day of the
      previous month. If a valuation for private securities is not available through the custodian, the Firm will
      typically rely on the valuation provided by the issuer. Because valuations may only be provided periodically
      (including monthly, quarterly or even annually), the Firm can be billing on a valuation that would be
      different if updated. That valuation can be higher or lower depending on the increase or decrease in value
      of the private investment. The Firm bills on cash unless otherwise stated. The Firm does not make fee
      adjustments for deposits and withdrawals. The specific fee to be assessed will be outlined in the Advisory
      Agreement to be signed by the client.

      Total Wealth Asset Management Client Service Offerings Fees:

      VCM charges an annual fee of 1.00% with a $250,000 account minimum for this service.

      Total Access Asset Management Client Service Offerings Fees:

      VCM charges an annual fee of 1.00% with a $10,000 account minimum or a $500 monthly systematic
      deposit for this service.

      Third Party Asset Management:

      For VCM’s third-party asset management service, the Firm charges a maximum fee of 0.75% of the assets
      under management. The client’s primary advisor may charge a fee on top of the Firm’s third-party asset
      management fee, but that fee will not exceed 1.25%. The total fee assessed by VCM is a combination of
      VCM’s and client’s primary advisor fee and shall not exceed 2.00% for any client. The fees to be assessed
      will be outlined in the advisory agreement and will break down the fee paid to VCM and to the primary
      advisor.

      Other Services Fees

      Standalone Financial Planning & Consulting Fees:

      VCM also provides financial planning and consulting services on a standalone basis out (outside of the
      financial planning and consulting services mentioned above). The total estimated fee, as well as the ultimate
      fee charged, is based on the scope and complexity of the engagement. The fee-paying arrangements will be
      determined on a case-by-case basis and will be detailed in the signed consulting agreement. VCM will not
      require a retainer exceeding $1,200 when services cannot be rendered within 6 months.

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      Portfolio Review Service:

      The Fee for the Portfolio Review Service will be the following: $250 for up to five accounts comprised of
      ETFs only or $375 for more than five accounts comprised of ETFs only or accounts with individual equities.

      Retirement Plan Consulting:

      VCM Retirement Plan Consulting services are provided for a flat fee basis, or a fee based on the percentage
      of Plan assets under management. The total estimated fee, as well as the ultimate fee charged, is based on
      the scope and complexity of the engagement. The flat fees will not exceed $10,000. Fees based on a
      percentage of managed Plan assets will not exceed 1.00%. Additionally, the Firm requires a minimum
      annual fee of $1,500 for our Retirement Plan Consulting services. Unlike the standard fee timing referenced
      above, all fees for this service will be paid monthly or quarterly in arrears. However, the exact fee-paying
      arrangements will be determined on a case-by-case basis and will be detailed in the signed agreement.
...

Item 7. Types of Clients
      VCM offers services to Individuals, High Net Worth Individuals, Trusts, Estates, Corporations, Limited
      Liability Companies, and other business types.

      VCM’s Solo Plan category is reserved for planning for one person. If an individual is married or wishes to
      include more than one person on the plan, then they will be required to select Family Plan or Retirement
      Plan. VCM does not have any other restrictions for Family Plan to Entrepreneur Elite Plan. Account
      minimum for Total Wealth Asset Management is $250,000 and Account minimum for Total Access Asset
      Management is $10,000 account minimum or a $500 monthly systematic deposit.

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 Disclosure Brochure