Alsworth Capital Management LLC

Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client shall enter into one or more agreements that detail the responsibilities of ACM and the Client.

A. Fees for Advisory Services
Investment Management Services
Investment management fees are paid quarterly, at the end of each calendar quarter, pursuant to the terms of the
investment management agreement. Investment management fees are based on the market value of assets under
management at the end of each quarter. Fees are based on the following schedule:

                  Assets Under Management ($)          Annual Rate (%)
                    First $2,000,000                       1.00%
                    Over $2,000,000                        0.50%

The investment management fee in the first quarter of service is prorated from the inception date of the account[s]
to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will
take into consideration the aggregate assets under management with the Advisor. All securities held in accounts
managed by ACM will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the
Custodian’s valuation to ensure accurate billing. Fees for advisory services rendered to non-profit organizations are
charged an annual asset-based fee of 0.50%. Fees may be negotiable depending on size and complexity.

Retirement Plan Advisory Services
Fees for retirement plan advisory services are charged an annual asset-based fee of 0.50%. Fees may be
negotiable depending on the size and complexity of the Plan.

B. Fee Billing
Investment Management Services
Investment management fees are calculated by the Advisor and deducted from the Client’s account[s] at the
Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted
from the Client’s account[s] at the respective calendar quarter end date. The amount due is calculated by
applying the calendar quarter rate (annual rate divided by the number of days in the year, multiplied by the
number of days in the quarter) to the total assets under management with ACM at the end of each calendar
quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of
the investment management fee. In addition, the Advisor will provide the Client a report itemizing the fee,
including the calculation period covered by the fee, the account value and the methodology used to calculate the
fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage
statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting
advisory fees to be deducted by ACM directly from their account[s] held by the Custodian as part of the
investment management agreement and separate account forms provided by the Custodian.

Retirement Plan Advisory Services
Fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the
terms of the retirement plan advisory agreement.

C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than ACM, in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all securities execution and
custody fees charged by the Custodian, as applicable. Certain custodians recommended by the Advisor do not
charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account
meets the terms and conditions of the Custodian's brokerage requirements. However, custodians typically
charge for mutual funds and other types of investments. The fees charged by ACM are separate and distinct
from these custody and execution fees.

                                           Alsworth Capital Management, LLC
                                                    4 West Market Street
                                                     Corning, NY 14830
                                                   Phone: (607) 973-2665
                                              http://www.AlsworthCapital.com

In addition, all fees paid to ACM for investment management services are separate and distinct from the
expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are
described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees
for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and
a possible distribution fee. A Client may be able to invest in these products directly, without the services of ACM,
but would not receive the services provided by ACM which are designed, among other things, to assist the Client
in determining which products or services are most appropriate for each Client’s financial situation and
objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by
ACM to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional
information.

D. Advance Payment of Fees and Termination
Investment Management Services
ACM is compensated for its investment management services at the end of the quarter, after investment
management services are rendered. Either party may terminate the investment management agreement, at any
time, by providing advance written notice to the other party. The Client may also terminate the agreement within five
(5) business days of signing the Advisor’s investment management agreement at no cost to the Client. After the
five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and
...

Item 7 – Types of Clients
ACM provides investment advisory services to individuals, high net worth individuals, trusts, estates, charitable
organizations, corporations and retirement plans. Alsworth Capital Management generally requires a minimum
relationship size of $500,000 to effectively implement its investment process. Additionally, ACM generally
requires a $2,000,000 minimum account size requirement for Retirement Plan Advisory Service Clients. These
amounts may be waived or reduced at the sole discretion of the Advisor.