Bontempo OHLY Capital Management LLC

TYPES OF CLIENTS
The client profile that Advisor generally provides investment advice to includes but is not limited
to high-net-worth individuals and families, trusts, estates, and pension and profit-sharing plans.

TYPES OF INVESTMENTS
Advisor offers advice on the following: exchange-listed securities, over-the-counter securities,
corporate debt securities (other than commercial paper), municipal securities, United States
Government securities, and agency securities.

METHODS OF ANALYSIS, SOURCES OF INFORMATION, AND INVESTMENT
STRATEGIES
Advisor’s security analysis method can be described as strict quantitative modeling. The main
sources of information Advisor uses include large security databases, research materials prepared
by others, and financial software, data, and media. The investment strategies used to implement
any investment advice given to clients include long-term purchases (securities held at least a year)
and short-term purchases (securities sold within a year).

EDUCATION AND BUSINESS STANDARDS
Advisor requires a minimum of 5 years investment experience and/or a relevant four-year college
degree and/or a major professional investment designation (CFA® or CFP®) before any person in
an advisory role is permitted to determine or give investment advice to clients.

EDUCATION AND BUSINESS BACKGROUND
      Ormand A. Bontempo
      Bontempo graduated from The Catholic University of America, magna cum laude.
      Bontempo has served as President of Bontempo Ohly Capital Management, LLC (BOCM)
      since its inception in October 2004 to present. Prior to BOCM, Bontempo was employed as
      a financial advisor at Merrill Lynch and at Wachovia Securities.
      John F. Ohly, CFP®
      Ohly graduated from the University of Maryland. Ohly has served as Vice President of
      Bontempo Ohly Capital Management, LLC (BOCM) since its inception in October 2004 to
      present. Prior to BOCM, Ohly was employed as a financial advisor at Merrill Lynch and at
      Wachovia Securities.

OTHER BUSINESS ACTIVITIES
Advisor is not actively engaged in a business other than giving investment advice. Advisor does
not sell products or services other than investment advice to clients. The principal business of
Advisor or its principal executive officers does not involve anything other than providing
investment advice.

OTHER FINANCIAL INDUSTRY ACTIVITIES OR AFFILIATIONS
Advisor has no other financial industry activities or affiliations.

PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
Advisor may buy or sell for itself securities that it also recommends to clients.

CONDITIONS FOR MANAGING ACCOUNTS
Advisor provides investment supervisory services, manages investment advisory accounts, and
performs financial planning. Advisor does not assess a minimum annual fee to provide ongoing
asset management services. However, households with less than $500,000 in investable assets will
be evaluated on a case-by-case basis to determine suitability for Advisor’s programs. All potential
households, regardless of asset amount, will be evaluated to determine suitability for BOCM.