Anchor Capital Management LLC

Item 5.        Fees and Compensation

Portfolio Management Services

For this service, we charge an annual fee based on a percentage of assets under our management. Fees
will not exceed 1.20% of assets under management.

Depending on the particular arrangement with each client, we will either invoice clients or directly
debit their custodial accounts for portfolio management fees. If the fee is directly debited, we will
adhere to the following procedure:

   1. We will obtain a written authorization from the client, permitting our fees to be paid directly
      from the client's account held by an independent custodian;

Quarterly, we calculate contractual fee and bill directly to client custodian for payment. Client is
responsible for any comparisons.
    2. We will inform the client that it is the client’s responsibility to verify the accuracy of the fee
       calculation and that the custodian will not determine whether the fee is properly calculated; and

   3. The custodian will agree to send to the client a statement, at least quarterly, indicating all
      amounts disbursed from the account including the amount of advisery fees paid directly to us.

Portfolio management fees are billed in advance at the beginning of each quarter, based upon the
billable balance on the last day of the previous calendar quarter.

Financial Planning Services

Financial Planning Services are provided for investment advisery clients only.

Consulting Services

Note that consulting services are offered only to those who already receive portfolio management
services and are not offered on a standalone basis. For this service, we charge an initial first-meeting
deposit of $500 and subsequently, an hourly fee, of $300 per hour. An estimate of the total amount will
be provided to the client prior to the commencement of the engagement. The first-meeting deposit is
payable in advance of the scheduled meeting and is not refundable. A written agreement for each
project will be executed between ACM and the client.

Consulting fees are due and payable once we deliver the contracted-for work product to the client. An
advance retainer may be required under certain circumstances.

Fees in General

We may group certain related client accounts for the purposes of determining the account size and/or
annualized fee.

Certain legacy client agreements may be governed by fee schedules different from those listed above.

Under no circumstances will we earn fees in excess of $1,200 for a period of more than six months in
advance of services rendered.

Account Termination

Clients will have a period of five (5) business days from the date of signing the agreement to
unconditionally rescind the agreement and receive a full refund of all fees, other than the non-
refundable items for Consulting services, as specified above. Thereafter, the client may terminate the
agreement by providing us with a 30-day written notice at our principal place of business. Upon
termination of any account, any prepaid, unearned fees will be promptly refunded, other than the non-
refundable items for Consulting services, as specified above, and any earned, unpaid fees will be due
and payable. Clients should contact Anne Chernish directly with any questions regarding refunds.

Mutual Fund and ETF Fees and Expenses: All fees paid to our firm for investment advisery services
are separate and distinct from the fees and expenses charged by mutual funds and 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. A client
could invest in a mutual fund or an ETF directly, without the services of our firm. In that case, the
client would not receive the services provided by us which are designed, among other things, to
assist the client in determining which mutual fund or funds or ETFs are most appropriate to each
client's financial condition and objectives. Accordingly, the client should review both the fees
charged by the funds and ETFs and the fees charged by us to fully understand the total amount of
fees to be paid by the client and to thereby evaluate the advisery services being provided.

In limited circumstances, primarily for smaller accounts or specific portfolio construction needs, the
firm may utilize mutual funds or exchange‑traded funds in client portfolios. When these vehicles are

used, clients incur both the advisory fee charged by the firm and the internal management fees and
expenses of the fund. This results in a layered or “double” management fee structure. The firm uses
such vehicles infrequently and does not utilize mutual funds or ETFs that charge sales loads,
commissions, or distribution (12b‑1) fees. The firm does not accept commissions of any kind.

Certain mutual funds charge “front-end loads” or “back-end loads” which are paid to
investment intermediaries as sales commissions. As such, these sales charges are not part of a mutual
fund's operating expenses and are deducted from the investment amount, thus lowering the size of the
investment. Certain mutual funds also charge annual marketing or distribution fees. These 12b-1 fees
are considered an operational expense and, as such, are included in a fund's expense ratio.
We attempt to avoid all front or back end-loaded funds. We utilize no-load or no 12b1 funds, except
for hold if already owned noted above.

Brokerage, Custodial, and Third-Party Manager Fees

In addition to advisery fees paid to our firm, clients will also be responsible for all transaction,
brokerage, trade-away and custodial fees incurred as part of their account management. Please see

Item 7.        Types of Clients

Our firm generally provides advisery services to individuals, trusts, estates and charitable
organizations.

We normally impose a minimum account size of $500,000 for Portfolio Management services, but may
waive this minimum for clients, based on criteria such as anticipated future earning capacity,
anticipated future additional assets, dollar amount of assets to be managed, related accounts, account
composition, and competitive considerations.