Vanguard Capital Wealth Advisors LLC

ITEM 5 - FEES AND COMPENSATION

Investment Management Fees and Compensation

Our Firm charges an advisory fee as compensation for providing Investment Management
services on client accounts. These services include advisory services, investment
supervision, and other account-maintenance activities. Our custodian charges custodial
fees, redemption fees, retirement plan and administrative fees or commissions. Financial
planning services by our firm are included in advisory fees outlined below. See Additional
Fees and Expenses below for additional details on fees that may apply to your account.

The fees for investment management are based on an annual percentage of assets under
management and are applied to the household asset value on a pro-rata basis and billed
quarterly in arrears. The quarterly fee will be calculated on the quarter end balance of the
account. Fees are assessed on all assets under management, including securities, cash
and money market balances. Margin account balances are not included in the fee billing.

          Vanguard Capital Wealth Advisors, LLC –999 18 St, Suite 3000, Denver, Colorado 80202
                                       FORM ADV 2A Brochure

Our maximum investment advisory fee is 1.50% or we may negotiate a lower advisory
fee. The specific advisory fees are set forth in your Investment Management Agreement.
Fees may vary based on the size of the account, complexity of the portfolio, extent of
activity in the account or other reasons agreed upon by us and you as the client. In certain
circumstances, our fees and the timing of the fee payments may be negotiated. Our
employees and their family related accounts are charged a reduced fee for our services.

Unless otherwise instructed by the Client, we will aggregate related client accounts for
the purposes of determining the account size and annualized fee. The common practice
is often referred to as “house-holding” portfolios for fee purposes and may result in lower
fees than if fees were calculated on portfolios separately. Our method of house-holding
accounts for fee purposes looks at the overall family dynamic and relationship. When
applicable and noted in Appendix A of the Investment Management Agreement, legacy
positions will also be excluded from the fee calculation.

The independent qualified custodian holding your funds and securities will debit your
account directly for the advisory fee and pay that fee to us. You will provide written
authorization permitting the fees to be paid directly from your account held by the
qualified custodian. Further, the qualified custodian agrees to deliver an account
statement to you on a monthly basis indicating all the amounts deducted from the
account including our advisory fees.

Either Vanguard or you may terminate the management agreement immediately upon
written notice to the other party. The management fee will be pro-rated to the date of
termination, for the quarter in which the cancellation notice was given and the fee will be
billed to your account. Upon termination, you are responsible for monitoring the
securities in your account, and we will have no further obligation to act or advise with
respect to those assets. In the event of client’s death or disability, Vanguard will continue
management of the account until we are notified of client’s death or disability and given
alternative instructions by an authorized party.

We will not require prepayment of more than $1200 in fees per client, six (6) or more
months in advance of providing any services.

Consulting Fees

We provide consulting services for clients who need advice on a limited scope of work.
We will negotiate consulting fees with you. Fees for Consulting Services will vary based
on the extent and complexity of the consulting project.

          Vanguard Capital Wealth Advisors, LLC –999 18 St, Suite 3000, Denver, Colorado 80202
                                       FORM ADV 2A Brochure

Vanguard Capital's standard hourly billing rate for non-portfolio management clients
seeking independent financial consultation, on a per project basis, at a rate of $200.00
per hour.

Either party may terminate the agreement. Upon termination, fees will be prorated to
the date of termination and any earned portion of the fee will be billed to you as described
in the Agreement.

Additional Fees and Expenses

In addition to the advisory fees paid to our Firm, clients also incur certain charges imposed
by other third parties, such as broker-dealers, custodians, trust companies, banks and
other financial institutions (collectively “Financial Institutions”). These additional charges
include custodial fees, charges imposed by a mutual fund or ETF in a client’s account, as
disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses),
deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic
fund fees, and other fees and taxes on brokerage accounts and securities transactions.
Our brokerage practices are described at length in Item 12, below. Neither our Firm nor
its supervised persons accept compensation for the sale of securities or other investment
products. Further, our firm does not share in any of these additional fees and expenses
outlined above.

ITEM 7 - TYPES OF CLIENTS

We provide investment advice to individuals and high net worth individuals. The
minimum initial account value for opening an account with our firm is $50,000. We
reserve the right to make exceptions, at our discretion, on a case by case basis.