1932 Investment Management LLC

ITEM 5 – FEES AND COMPENSATION

Advisory Fees
1932 charges an annual investment advisory fee based on the total assets under management ranging from
.75% to 1.00% depending on the level of assets.

This is a tiered or breakpoint fee schedule, meaning the entire account is charged the same management
fee. Fees are billed monthly in arrears based on the amount of assets managed as of the close of business
on the last business day of the previous billing period. The custodian determines fair market value for fee
calculation purposes.

Fees are negotiated on an individual basis at the time of engagement for such services. Factors considered
in determining the fees charged generally include, without limitation, the complexity of the portfolio, amount
of assets to be placed under management, related accounts, or other special requirements. This practice
creates a conflict of interest because some clients will pay more than other clients for similar advisory
services.

Payment of Fees
Fees for advisory services are generally calculated as a percentage of the total market value of your managed
assets. The total fee is comprised of two components: (a) the advisory fee, and (b) any fees associated with
the use of a TPM.

Fees for advisory services are payable monthly in arrears. The percentage of the assets under management
fee is based on an account’s month-end value. Fee amounts are fully disclosed in each client’s Intercompany
Services Agreement. All current fees are paid via intercompany transfers.

The basis for the assets under management fee includes cash in the managed accounts including accrued
interest. Inflows and outflows occurring during the month are not pro-rated. Accounts managed for partial
months are charged based on the number of days they were actively managed.

Third Party Management (TPM) Fees
For TPM services, the method of payment will be disclosed in the TPM’s Form ADV Part 2A.

1932, in its sole discretion, may charge a lesser investment advisory fee based upon certain criteria (e.g.,
historical relationship, type of assets, negotiations with Clients, etc.).

For all services, you may terminate your engagement with 1932 within five (5) business days of signing an
Advisory Agreement with no obligation and without penalty. After the initial (5) business days, the Advisory
Agreement may be terminated by 1932 with thirty (30) days written notice to you and by you at any time
with written notice to 1932. For accounts opened or closed mid-billing period, fees will be prorated based
on the number of days services are provided during the given period.

You will be provided with notice, in writing, of any changes in fees in accordance with the terms set forth in
the Advisory Agreement.

Other Fees and Expenses
Custodians may charge brokerage commissions, transaction fees, and other related costs on the purchases
or sales of mutual funds, equities, bonds, options, margin interest, and exchange-traded funds. Mutual funds,
money market funds, and exchange-traded funds may also charge internal management fees, which are
disclosed in the fund’s prospectus. 1932 does not directly receive any compensation from these fees. All of
these fees are in addition to the management fee you pay to 1932. For more details on the brokerage
practices, see Item 12 of this Brochure.

ITEM 7 – TYPES OF CLIENTS

1932 and its IARs provide advisory services to the following types of clients:

    •   Insurance Companies
    •   Corporations or other Businesses
    •   Pension and Profit-Sharing Plans
    •   Charitable Organizations

1932 provides investment advice to its parent company, affiliates and selected joint ventures. 1932 does not
currently provide advisory services to unaffiliated institutional investors. 1932 does not have any minimum
account size requirements for opening or maintaining an advisory account. However, certain TPMs utilized
by 1932 may have account minimums that will be disclosed to the client in the TPM’s Form ADV Part 2 and
Advisory Agreement.