Athena Investment Management

Item 5: Fees and Compensation

        Advisory fees are determined on a percentage of assets under management basis and
billed quarterly, after services are rendered. For billing purposes, assets under management are
calculated as the average of the beginning and ending values, with a weighted average method
employed when large additions or withdrawals occur during the billing period. Athena’s
management fee rises as assets increase, but declines as a percentage of assets under
management, according to the following schedule:

       1.00% per year of total assets under management up to $250,000.
       0.75% per year of assets under management from $250,000 to $500,000.
       0.50% per year of assets under management from $500,000 to $1,000,000.
       0.25% per year of assets under management from $1,000,000 to $5,000,000.

       0.167% per year of assets under management from $5,000,000 to $10,000,000.
       0.10% per year of assets under management over $10,000,000.

        Other client fees may differ due to prior negotiations. In certain cases, single rate fees are
negotiated. In this circumstance, client fees as billed are the lesser of the negotiated rate or the
rate as computed by the standard fee table.

       Client fees are either billed directly to the client or can be deducted directly from one or
more of the client’s investment accounts if this authority is granted by the client.

       Other investment costs, such as brokerage transaction charges or mutual fund operating
expenses, are also borne by the client. This is discussed further in Item 12: Brokerage Practices,

       Client fees are billed after each quarterly billing period, never before, or, in cases of
termination, after complete conclusion of services.

       No one at or directly affiliated with Athena Investment Management ever receives
compensation for the sale or placement of any security or investment product in any client
account.

       Under specific client direction and agreement, Athena may provide additional
administrative services on an hourly rate basis.

Item 7: Types of Clients

         Athena currently manages portfolios only for individual (including families) clients or
entities, such as 401K accounts, or LLCs controlled by an individual, and for charitable
institutions. Account types include individual, high-net-worth individual, joint tenants, trust,
IRAs, pension and profit-sharing, 401Ks, educational saving accounts and 529s, variable annuity
accounts, LLCs, charitable foundations and donor-advised funds. Athena can manage
investment accounts held in virtually any title, as long as the account holder, trustee, custodian,
or entity, has the power to assign a limited power of attorney to a 3 rd party investment manager.