ACSB Capital Management LLC

Fees and Compensation

Please refer to the Advisory Business section in this brochure for information on our advisory fees, fee
deduction arrangements, and refund policy according to each service we offer.

Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in mutual
funds and exchange traded funds. The fees that you pay to our firm for investment advisory services are
separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds
(described in each fund’s prospectus) to their shareholders. These fees will generally include a management
fee and other fund expenses. You will also incur transaction charges and/or brokerage fees when purchasing or
selling securities. These charges and fees are typically imposed by the broker-dealer or custodian through
whom your account transactions are executed. We do not share in any portion of the brokerage
fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost you will

incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. For
information on our brokerage practices, please refer to the “Brokerage Practices” section of this brochure.

We may trade client accounts on margin. Fees for advice and execution on these securities are based on the
total asset value of the account, which includes the value of the securities purchased on margin. While a
negative amount may show on a client’s statement for the margined security as the result of a lower net market
value, the amount of the fee is based on the absolute market value. This could create a conflict of interest
where we may have an incentive to encourage the use of margin to create a higher market value and therefore
receive a higher fee. The use of margin may also result in interest charges in addition to all other fees and
expenses associated with the security involved.

                    Performance-Based Fees and Side-By-Side Management

We do not accept performance-based fees or participate in side-by-side management. Side-by-side
management refers to the practice of managing accounts that are charged performance-based fees while at the
same time managing accounts that are not charged performance-based fees. Performance-based fees are fees
that are based on a share of capital gains or capital appreciation of a client’s account. Our fees are calculated as
described in the Advisory Business section above, and are not charged on the basis of a share of capital gains
upon, or capital appreciation of, the funds in your advisory account.

Types of Clients

We offer investment advisory services to individuals, pension and profit sharing plans, trusts, estates, charitable
organizations, corporations, and other business entities.

In general, we require a minimum of $3,000,000 to open and maintain an advisory account. At our discretion,
we may waive this minimum account size. For example, we may waive the minimum if you appear to have
significant potential for increasing your assets under our management. We may also combine account values
for you and your minor children, joint accounts with your spouse, and other types of related accounts to meet
the stated minimum.

                 Methods of Analysis, Investment Strategies and Risk of Loss

We may use one or more of the following methods of analysis or investment strategies when providing
investment advice to you:

       Fundamental Analysis– involves analyzing individual companies and their industry groups, such as a
        company’s financial statements, details regarding the company’s product line, the experience and
        expertise of the company’s management, and the outlook for the company’s industry. The resulting
        data is used to measure the true value of the company’s stock compared to the current market value.
       Cyclical Analysis – a type of technical analysis that involves evaluating recurring price patterns and
        trends.
       Long Term Purchases–securities purchased with the expectation that the value of those securities will
        grow over a relatively long period of time, generally greater than one year.

       Short Term Purchases – securities purchased with the expectation that they will be sold within a
        relatively short period of time, generally less than one year, to take advantage of the securities’ short-
        term price fluctuations.
       Margin Transactions – a securities transaction in which an investor borrows money to purchase a
        security, in which case the security serves as collateral on the loan.
       Trading Options – which is purchasing the right to short or go long on an underlying marketable
        security or index for the purpose of protecting a client’s portfolio value by purchasing puts when the
        financial markets are projected to decline over a certain a period of time or purchasing calls when the
        financial markets are projected to increase over a specified period of time.

Risks of Methods of Analysis
Fundamental Analysis - The risk of fundamental analysis is that information obtained may be incorrect and the
analysis may not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If
securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable
performance.

Cyclical Analysis - Economic/business cycles may not be predictable and may have many fluctuations between
long term expansions and contractions. The lengths of economic cycles may be difficult to predict with accuracy
and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the
changing value of securities that would be affected by these changing trends.

Investment Strategy and Tax Disclosures
Our investment strategies and advice may vary depending upon each client’s specific financial situation. As
such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time
horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. Your
restrictions and guidelines may affect the composition of your portfolio.

Our strategies and investments may have unique and significant tax implications. However, unless we
specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of
your assets. Regardless of your account size or any other factors, we strongly recommend that you
continuously consult with a tax professional prior to and throughout the investing of your assets.

Moreover, as a result of revised IRS regulations, custodians will begin reporting the cost basis of equities
acquired in client accounts on or after January 1, 2011. Your custodian will default to the FIFO (First-In First-
Out) accounting method for calculating the cost basis of your investments. You are responsible for contacting
your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes
another accounting method is more advantageous, please provide written notice to our firm immediately and
we will alert your account custodian of your individually selected accounting method. Please note that decisions
about cost basis accounting methods will need to be made before trades settle, as tax law requires that the
cost basis method remain unchanged after settlement.

Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or
guarantee that our services or methods of analysis can or will predict future results, successfully identify market
tops or bottoms, or insulate clients from losses due to market corrections or declines. You understand that our
investment recommendations for your account are subject to various market, currency, economic, political and
business risks, and that those investment decisions will not always be profitable. We cannot offer any
guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an
indication of future performance.

Recommendation of Particular Types of Securities
As disclosed under the Advisory Business section above, we recommend all types of securities and we do not
necessarily recommend one particular type of security over another since each client has different needs and
different tolerance for risk. Each type of security has its own unique set of risks associated with it and it would
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