Brooks Moore & Associates Inc

Fees and Compensation

The following types of fees will be assessed:

Asset Management – Fees are charged in arrears and are based primarily on asset size and the
level of complexity of the services provided. In individual cases, BMA has the discretion to
negotiate fees that are lower than the standard fee shown or to waive fees. Fees are not based on
the share of gains or capital appreciation of the funds or any portion of the funds. Comparable
services for lower fees may be available from other sources. Fees for the initial quarter will be
prorated based upon the number of calendar days in the calendar quarter that the advisory
agreement is in effect. Fees are based on the market value of the assets on the last business day
of the quarter. Annual fees range from .50% - 1.00% depending on the amount of assets under
management (“AUM”) – See chart below. In lieu of the fee schedule below, a fixed fee lower
than the stated fee in the fee schedule may be negotiated. Many of our clients pay fees that are
less than our standard fee schedule.

Fee Schedule for Asset Management:

   Total Account Value                                Maximum Annual Advisory Fee

 Up to $500,000                                                    1.00%

 Next $2,500,000                                                   0.75%

 Over $3,000,000                                                   0.50%

When authorized in the client agreement, the account custodian withdraws BMA’s advisory fees
directly from the clients’ accounts according to the custodian’s policies, practices, and
procedures. The custodian in turn remits these fees to BMA. The custodial statement includes
the amount of any fees paid directly to BMA to manage the account. Brooks, Moore &
Associates, Inc. also sends quarterly invoices detailing the manner and amount of advisory fees
to all clients. You should compare the statement we send to your custodian/broker-dealer’s
statement and verify the calculation of fees. Your custodian/broker-dealer does not verify the
accuracy of fee calculations. If the account does not contain sufficient funds to pay advisory
fees, BMA has limited authority to sell or redeem securities in sufficient amounts to pay advisory
fees. With the exception of IRA accounts, clients may reimburse the account for advisory fees
paid to BMA.

Fees are charged in arrears on a quarterly basis, meaning that advisory fees for a quarter are
charged on the first day of the quarter, for the amount of assets under management as of the last
business day of the previous quarter. Clients may terminate investment advisory services
obtained from BMA, without penalty, upon written notice within five (5) business days after
entering into the advisory agreement with BMA. The client is responsible for any fees and
charges incurred by the client from third parties as a result of maintaining the account such as

transaction fees for any securities transactions executed and account maintenance or custodial
fees. Thereafter, the client may terminate advisory services upon 30 days’ written notice
delivered to and received by BMA. Clients who terminate investment advisory services during a
quarter are charged a prorated advisory fee based on the date of BMA’s receipt of client’s written
notice to terminate. Any earned but unpaid fees are immediately due and payable.

Additional Fees and Expenses

In addition to advisory fees paid to BMA as explained above, clients may pay custodial service,
account maintenance, transaction, and other fees associated with maintaining the account. These
fees vary by broker and/or custodian. Clients should ask BMA for details on transaction fees or
other custodial fees specific to their account, as these fees are not included in the annual advisory
fee. BMA does not share any portion of such fees. Additionally, for any mutual funds
purchased, the client may pay their proportionate share of the funds’ distribution, internal
management, investment advisory and administrative fees. Such fees are not shared with BMA
and are compensation to the fund manager.

Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that
would not exist if the purchase or sale were made directly with the mutual fund company.
Mutual funds held in broker-dealer accounts also charge management fees. These mutual fund
management fees may be more or less than the mutual fund management fees charged if the
client held the mutual fund directly with the mutual fund company.

Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal
underwriter, or a distributor without purchasing the services of BMA or paying the advisory fee
on such shares (but subject to any applicable sales charges). Certain mutual funds are offered to
the public without a sales charge. In the case of mutual funds offered with a sales charge, the
prevailing sales charge may be more or less than the applicable advisory fee. However, clients
would not receive BMA’s assistance in developing an investment strategy, selecting securities,
monitoring performance of the account, and making changes as necessary.

Please refer to Item 12 “Brokerage Practices” of this brochure for additional information.

Form ADV, Part 2A, Item 6

Performance-Based Fees and Side-By-Side Management

BMA does not charge performance-based fees or participate in side-by-side management. Side-
by-side management refers to the practice of managing accounts that are charged performance-
based fees while at the same time managing accounts that are not charged performance-based
fees. Performance-based fees are fees that are based on a share of capital gains or appreciation
of the assets of a client. Our fees are calculated as described in Fees and Compensation section
above, and are not charged on the basis of performance of your advisory account.

Form ADV, Part 2A, Item 7

Types of Clients

BMA’s client base consists primarily of high net worth individuals; however, we also manage
investment accounts for pension and profit sharing plans, 401(k) plans, charitable organizations,
and corporations or other businesses. In general, a minimum of $250,000 is required to open an
advisory account. At our discretion, we may waive the minimum account size. For example, we
may waive the minimum if you appear to have significant potential for increasing your assets
under management. We may also combine account values for you and your spouse and other
types of related accounts to meet the stated minimum.

Form ADV, Part 2A, Item 8

Methods of Analysis, Investment Strategies, and Risk of Loss

BMA’s methods of analysis and investment strategies incorporate the client’s needs and
investment objectives, time horizon, and risk tolerance. BMA is not bound to a specific
investment strategy for the management of investment portfolios, but rather considers the risk
tolerance levels pre-determined and gathered at the account opening, as well as on an on-going
basis. Examples of methodologies that our investment strategies may incorporate include:

Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix
of asset classes and the efficient allocation of capital to those assets by matching rates of return
to a specified and quantifiable tolerance for risk.

Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount
of securities at regularly scheduled intervals, regardless of the price per share. This will
gradually, over time, decrease the average share price of the security. Dollar-cost averaging
lessens the risk of investing a large amount in a single investment at the wrong time.

Technical Analysis – involves studying past price patterns and trends in the financial markets to
predict the direction of both the overall market and specific stocks.

Long-Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year.

Short-Term Purchases – securities purchased with the expectation that they will be sold within a
relatively short period of time, generally less than one year, to take advantage of the securities’
short term price fluctuations.

Our strategies and investments may have unique and significant tax implications. Regardless of
your account size or other factors, we strongly recommend that you continuously consult with a
tax professional prior to and throughout the investing of your assets.

Investing in securities involves risk of loss that clients should be prepared to bear. Although we
manage your portfolio with strategies and in a manner consistent with your risk tolerances, there

can be no guarantee that our efforts will be successful. You should be prepared to bear the risk
of loss.

All investments involve the risk of loss, including (among other things) loss of principal, a
reduction in earnings (including interest, dividends, and other distributions), and the loss of
future earnings. These risks include market risk, interest rate risk, issuer risk, and general
economic risk. Regardless of the methods of analysis or strategies suggested for your particular
investment goals, you should carefully consider these risks, as they all bear risks.

Form ADV, Part 2A, Item 9