Aspen Investment Management Inc

ITEM 5: FEES AND COMPENSATION
Portfolio Management & Participant Account Management
       Although our fees for our services may be negotiated under certain circumstances, our
standard fee schedule is as follows:
                   Assets                                   Annual Fee
                   Up to $2,000,000                         1.00%
                   $2,000,001 to $4,999,999                 0.80%
                   Over $5,000,000                          0.60%

        We determine fees based on your initial invested account value, as reported by your account
custodian, and the value of your account at the end of each subsequent billing period. We pro-rate
fees for the first billing period based on the day the account is funded. Thereafter, we bill our fees
quarterly in advance, as specified in our Client Services Agreement with you. We calculate fees
based upon the custodian reported value (market value or fair market value in the absence of market
value) of your account on the last business day of the previous quarter. Our fees do not include
brokerage commissions, transaction fees, and other related costs and expenses incurred in
connection with providing portfolio management services to you. Cash balances are included in
fee calculations. This includes the cash positions held while we begin the investment process,
which are larger as we fully implement your investment strategy over time.
       Prorated adjustments will be made for investments or withdrawals, in amounts of $25,000
or more, during a quarterly billing period.
Limited Negotiability of Advisory Fees:
        Although we have established the above fee schedule, we retain the discretion to negotiate
alternative fees on a client-by-client basis. The client’s 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. Additionally, the client may negotiate an

Form ADV Part 2A                               Page 5                 Aspen Investment Management, Inc.

alternative fee on the management of individual securities and unsolicited trade requests. The
specific annual fee schedule will be identified in the Client Services Agreement.
       We may group certain related client accounts for the purposes of achieving the minimum
account size requirements and determining the annualized fee.
       Discounts, which are not generally available to our advisory clients, may be offered to
family members and friends of associated persons of our firm.
Participant Account Management

For participant account management, the client will receive a fee invoice that details how the fee
was calculated, the amount on which the calculation was based, the period the fee covered and the
fee. The fee will be deducted from a non-qualified account set up through the firm’s custodian.
Mutual Fund /ETF Fees:
        All fees paid to us for portfolio management services are separate and distinct from the fees
and expenses charged by mutual funds and/or 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.
       Accordingly, you should review both the fees charged by the funds and our fees to fully
understand the total amount of fees to be paid and to thereby evaluate the advisory services being
provided.
Termination of the Advisory Relationship:
        A client agreement may be canceled at any time, by either party, for any reason upon receipt
of 30 days written notice. As disclosed above, certain fees are paid in advance of services provided.
Upon termination of any account, any prepaid, unearned fees will be promptly refunded. In
calculating a client’s reimbursement of fees, we will pro rate the reimbursement according to the
number of days remaining in the billing period.
Grandfathering of Minimum Account Requirements.
       Pre-existing advisory clients are subject to the firm’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 will differ among clients.
Direct Billing to Your Custodian
       You may elect to be billed directly for fees or to authorize us to directly debit fees from
your accounts. Generally, our clients authorize us under Client Service Agreement to directly
deduct our fees from the client’s account. If you provide us with such authorization, the custodian’s
periodic statements will show each fee deduction from your account. You may withdraw this
authorization for direct billing of these fees at any time by notifying us or your custodian in writing.

Form ADV Part 2A                                Page 6                 Aspen Investment Management, Inc.

Retirement Rollover Conflicts of Interest
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts. The way we make money creates some conflicts of interest with your
interests, so we operate under a special rule that requires us to act in your best interest and not put
our interests ahead of yours.

ITEM 7: TYPES OF CLIENTS

       We provide portfolio management services to individuals, high net worth individuals, trusts
and estates, and charitable institutions.
        We impose certain conditions for starting an account. A minimum of $250,000 in cash
and/or securities is generally required to open an account. We may waive this requirement if, for
example, you have additional or related accounts that together exceed the minimum requirements
or as stated in “ITEM 5: FEES AND COMPENSATION”, we grand- father the minimum
account requirements and advisory fees in effect at the time a client entered into an advisory
relationship with us. These conditions are negotiable in light of your specific circumstances and
relationships with our firm and our principals.