Wright Cove Capital LLC

Item 5 - Fees and Compensation

                   INVESTMENT MANAGEMENT SERVICES FEES

In certain circumstances, all fees, account minimums and their applications to family
or other circumstances may be negotiable. Individual accounts for immediate family
members (such as husband, wife and dependent children) are aggregated, and the
fee is charged based on the total value of all family members’ accounts.

The specific manner in which fees are charged by WCC is established in a client’s
written investment management agreement with WCC. Generally, Investment
Management accounts will be billed in arrears at the end of each calendar quarter
based upon the value (market value or fair market value in the absence of market
value), of the client’s account at the end of the previous quarter. New accounts will
have the management fee pro-rated based on the number of days that the account
was open during the quarter.

Fees will be automatically deducted from the client’s managed account unless other
arrangements have been made in writing. If fees will be automatically deducted from
a client’s managed account, the client understands and acknowledges the following:

   a) Each time a fee is directly deducted from your account, we will send to your
      qualified custodian an invoice or statement of the amount of the fee to be
      deducted from your account;
   b) Your independent custodian sends statements at least quarterly to you
      showing all disbursements for your account, including the amount of the
      advisory fees paid to us;
   c) You provide authorization permitting us to be directly paid by these terms.

The typical annual fee for investment management services will be charged as a
percentage of assets under management, according to the schedule below:

      Total Assets under Management                              Annual Fee
      First $1 million ..........................................1.00%
      $1,000,001 - $5,000,000 ...........................0.50%
      Over $5,000,000 .......................................0.35%

Prior to implementation of a fee change, WCC must obtain an amended Investment
Management Agreement with the new agreed-upon fee executed in writing by the
client and WCC.

The minimum initial investment that WCC will accept from a new Investment
Management Services client is $1 million, which may be waived by WCC in its sole
discretion.

General Information

Limited Negotiability of Advisory Fees: Although Wright Cove Capital, LLC has
established the aforementioned fee schedule, we retain the discretion to negotiate
alternative fees on a client-by-client basis. Client facts, circumstances and needs are
considered in determining the fee schedule. These include the complexity of the
client, assets to be placed under management, anticipated future additional assets;
related accounts; portfolio style, account composition, reports, among other factors.
The specific annual fee schedule is identified in the contract between the adviser and
each client.

We may group certain related client accounts for the purposes of achieving the
minimum account size requirements and determining the annualized fee.

Termination of the Advisory Relationship: A client agreement may be canceled
at any time, by either party, for any reason upon receipt of written notice.

Mutual Fund Fees: All fees paid to Wright Cove Capital, LLC for investment advisory
services are separate and distinct from the fees and expenses charged by mutual
funds and/or ETFs to their shareholders. These fees and expense are called expense
ratios and are described in each fund's prospectus. These fees will generally include
a management fee and other fund expenses. For example, an expense ratio of 0.40
means that the mutual fund company or ETF charges 0.40% per year for their
services.   Performance figures quoted by mutual fund companies in various
publications are after their fees have been deducted.

Additional Fees and Expenses: In addition to our advisory fees, clients are also
responsible for the fees and expenses charged by custodians and imposed by broker
dealers, including, but not limited to, any transaction charges imposed by a broker
dealer with which an independent investment manager effects transactions for the
client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this
Form ADV for additional information.

Grandfathering of Minimum Account Requirements: Pre-existing advisory
clients are subject to Wright Cove Capital, LLC's minimum account requirements and
advisory fees in effect at the time the client entered into the advisory relationship.
Therefore, our firm's minimum account requirements may differ among clients.

Advisory Fees in General: Clients should note that similar advisory services may
(or may not) be available from other registered (or unregistered) investment advisers
for similar or lower fees.

Limited Prepayment of Fees: Under no circumstances do we require or solicit
payment of fees in excess of $500 more than six months in advance of services
rendered.

Item 7 - Types of Clients

WCC provides advisory services to individuals, high net worth individuals and their
families, and corporations or other business entities.

As previously disclosed in Item 5, the minimum initial investment that WCC will
accept from a new Investment Management Services client is $1 million, which may
be waived by WCC in its sole discretion.