Vavra Capital Management LLC

Item 5       Fees and Compensation
Reasonableness of Fees
VCM believes its fees are reasonable in light of the services offered and the experience and expertise of
Jason Vavra. Lower fees for comparable services may be available from other sources.
Variation of Fees
VCM does not impose a minimum account size, although the Firm reserves the right to do so in the
future, if such a minimum is necessary to assist clients in achieving their investment objectives. Pre-
existing advisory clients are subject to VCM's advisory fee schedule in effect at the time the client entered
into the advisory relationship, and/or executed its investment management agreement. Therefore, fee
schedules will differ among clients.
Clients will not be charged a total management fee over the 3% industry average.
VCM may group certain related client accounts for the purposes of determining the annualized fee.
Discounts, which are not generally available to our advisory clients, may be offered to family members
and friends of associated persons of our Firm.
VCM shall deliver a Firm Brochure to every client or prospective client. When a client has not received
a copy of the Brochure Documents at least 48 hours prior to signing an agreement, the client has five
business days in which to cancel, with no penalty, or for a full refund (if any funds were prepaid).
Automatic Fee Deduction
VCM may, as authorized by clients, direct each client’s account custodian to debit from the client’s
account and to pay VCM the advisory fee due from the client. In connection with this process, the Firm
shall:
   •   Initially obtain written authorization from the client permitting VCM’s fees to be paid directly
       from the client’s account.
   •   Communicate with each client’s custodian regarding the amount of fee to be paid to VCM on the
       client’s behalf (the “fee invoice”).
   •   Ensure that the independent custodian agrees to send the client, at least quarterly, a statement
       indicating all amounts disbursed from the account.
   •   Deliver a fee invoice to each client for the amount equal to the advisory fee due from the client
       for payment along with the calculation formula.
INVESTMENT SUPERVISORY SERVICES - INDIVIDUAL PORTFOLIO MANAGEMENT
FEES
VCM’s annual fees for Investment Supervisory Services are based upon a percentage of assets under
management and generally range from 0.50% to 1.00% billed quarterly in arrears. Although VCM has
established the aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a
client-by-client basis. Client facts, circumstances and needs will be considered in determining the fee
schedule. These include the complexity of the client’s advisory profile, assets to be placed under
management, anticipated future additional assets, related accounts, portfolio style, account composition,
and reporting requirements, among other factors. The specific annual fee schedule will be identified in
the contract between VCM and each client.

FINANCIAL PLANNING FEES
VCM's Financial Planning fee is determined based on the nature of the services being provided and the
complexity of each client’s circumstances. All fees are agreed upon prior to entering into a contract with
any client.
Our Financial Planning fees may be calculated and charged on an hourly basis of $250 per hour. Although
the length of time it will take to provide a Financial Plan will depend on each client's personal situation,
we will provide an estimate for the total hours at the start of the advisory relationship. Our Financial
Planning fees may be calculated and charged on a fixed fee basis, typically ranging from $250 to $2,000,
depending on the specific arrangement reached with the client. The fees are negotiable and may be
modified or changed by VCM upon advance written notice to the client. Fees are billed upon delivery of
the financial plan.
VCM reserves the right to reduce or waive the hourly fee and/or the minimum fixed fee if a financial
planning client chooses to engage us for our Portfolio Management Services.
PUBLICATION OF PERIODICALS OR NEWSLETTERS – FREE OF CHARGE
VCM publishes a newsletter providing general information on various financial topics including, but not
limited to, estate and retirement planning, market trends, etc. No specific investment recommendations
are provided in this newsletter and the information provided does not purport to meet the objectives or
needs of any individual recipient. This newsletter is distributed free of charge to our advisory clients.
GENERAL INFORMATION
Termination of the Advisory Relationship
A client agreement may be canceled at any time, by either party, for any reason upon receipt of 30 days
written notice. As disclosed above, certain fees are paid in advance of services provided. Upon
termination of any account, any prepaid, unearned fees will be promptly refunded. In calculating a
client’s reimbursement of fees, we will pro rate the reimbursement according to the number of days
remaining in the billing period.
Termination of the Financial Planning Agreement
The Financial Planning Agreement may be terminated by either party at any time without penalty upon
receipt of written notice by the other party. Such termination shall not, however, affect liabilities or
obligations incurred or arising from recommendations initiated under the Agreement prior to such
termination, including the provisions regarding arbitration, which shall survive any expiration or
termination of the Agreement.
Mutual Fund and ETF Fees
All fees paid to VCM for investment advisory services are separate and distinct from the fees and
expenses charged by mutual funds and/or Exchange Traded Funds (“ETFs”) to their shareholders. These
fees and expenses are described in each fund's prospectus. These fees will generally include a
management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales
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Item 7       Types of Clients
VCM provides investment advisory services to the following types of clients:
   •   Individuals
   •   High net worth individuals
   •   Banking or thrift institutions
   •   Pension and profit-sharing plans
   •   Charitable organizations
   •   Corporations or other businesses
   •   State or municipal government entities

VCM does not generally impose a minimum account size, although the Firm reserves the right to do so
in the future, if such a minimum is necessary to assist clients in achieving their investment objectives.
Please refer to the "Fees and Compensation" section (Item 5) of this Form ADV for additional
information.