Buckram Securities Ltd

Item 5 Fees and Compensation

5A.       Fees for Advisory Services.

We are compensated for our advisory services based upon a percentage of the assets you place
under management with us, except for client accounts with less than $50,000 in assets under
management which are charged a flat annual fee of $250.00.

Our fee schedule which sets forth or annual charges, is set forth below:

                                                               Annual Wrap Fee (Paid
          Account Balance                                      Quarterly In Arrears)**
          less than $50,000                                    $250. (Flat Fee)
          $50,000 - $250,000 *                                 1.00%
          $250,000 - $500,000*                                 .90%
          $500,000 - $1,000,000*                               .85%
          $1,000,000 and greater*                              .75%

Buckram Securities’ advisory fee is structured as a wrap fee meaning that clients participating in
our wrap fee program are charged a single asset-based fee (refer to the schedule above) which
covers both the advisory services provided and related transaction charges arising from resulting
brokerage transactions effected in client’s accounts based upon the advisory services we provide
to the client. Our advisory fee includes our ongoing discretionary investment management of your
accounts. While wrap fees typically include both an advisory fee and brokerage fee (i.e.,
commission or mark up) component, Buckram Securities waives virtually all brokerage charges
(including commissions, mark ups as well as other assorted brokerage-related fees and charges)
for its wrap fee clients.

Refer to the schedule below for a description of the brokerage commissions, mark ups and related
fees and charges which will be waived by Buckram Securities and therefore not charged to
advisory clients as part of our wrap fee nor separately charged to advisory clients in addition to
our wrap fee.

Brokerage Commissions, Fees and Charges Waived by Buckram Securities for Wrap Fee
Clients

      •   Commissions on Equities (including Preferred Stock), ETFs, Closed End Funds and
          Mutual Funds
      •   Mark Ups on Fixed Income Securities (i.e., Bonds)
      •   Annual IRA, Roth, Educational Maintenance Fee
      •   Simplified Employee Pension (SEP) Fees
      •   Simple Individual Retirement Account (IRA) Fees

      Household accounts receive a .005% fee reduction for all accounts.

      In calculating our asset-based wrap fee, we exclude all money market balances and individual bonds and notes
      held in a client’s account.

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4910-5587-1889, v. 1

Form ADV – Part 2A
Buckram Securities Ltd. (SEC No. 8-65939, 801-110136)

    •    Self-Employed 401(k) (Solo k) Maintenance Fees
    •    1099 Tax Statements Fee
    •    PES (Performance Evaluation System/Cost Basis Reporting) Annual Fee
    •    Dividend Reinvestment Monthly Fee
    •    Federal Funds Wire Fee
    •    Custody Inactivity Fee
    •    Quarterly Administrative Fee

Our advisory fees are negotiable, based on a client’s particular circumstances and considerations
such as the size of a client’s account, the amount of time a client has had an account with Buckram
Securities, the combined value of a client’s related advisory accounts, the total amount of business
a client conducts through Buckram Securities and the kind of securities in a client’s account.

As noted above, accounts from the same household are aggregated to achieve a lower annual-asset
based fee, if all such accounts are managed as a relationship, and then granted a discount of .005%
of such annual asset-based fee. Also, client money market balances and individual bonds and
notes held in client accounts are not included in the assets which our advisory fee is based upon.

Our advisory fee is assessed quarterly, in arears, and is based upon the market value of the client’s
accounts as of the close of business on the last business day of the calendar quarter, provided,
however, that (a) with respect to a client’s initial advisory fee, the fee shall be based upon the value
of the account as of the day the account’s assets are placed under the Buckram Securities’
supervision, pro-rated for the balance of the calendar quarter, and (b) if our clearing agent or other
third-party custodian only issues statements of the account as of the last business Friday of each
month (or the next preceding business day if such Friday is a holiday), then the date of the
statement so issued as of the last month in any calendar quarter shall be deemed to be the last
business day of such quarter for fees. Buckram Securities has engaged a third-party billing service
who will send a quarterly advice to the client and the custodian broker-dealer setting forth client’s
advisory fee due for each quarter and the manner in which such fee is calculated. Advisory fees
will be deducted directly from the client’s account and remitted to Buckram Securities pursuant to
the quarterly advice. To satisfy the payment of client’s advisory fee, funds will be deducted
directly from the client’s account and if necessary, from liquidating holdings in the following
order; (a) cash positions; (b) money market funds; or (c) current positions in the account. It should
be noted that some mutual funds and other securities that are purchased and sold for the client
accounts may have transaction fees, commissions, and/or redemption fees that will be charged to
client as noted in the corresponding prospectus for such security. Refer to Item 5C. below.

5B.    Deduction of Adviser Fees Directly from Client Accounts. As explained in 5A above,
advisory fees will be deducted directly form client accounts, in arrears, on a quarterly basis,
generally by the last day of the month following the end of the immediately preceding quarter.
...

Item 7 Types of Clients

Our advisory clients consist primarily of individuals, including high net worth individuals,
including simplified employee pension (SEP accounts), individual retirement accounts (IRAs),
self-employed 401(k) (Solo k) accounts and trusts. On occasion, our clients may also include
charitable organizations, corporations or other business entities.

Buckram Securities does not have a minimum account size requirement.

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4910-5587-1889, v. 1

Form ADV – Part 2A
Buckram Securities Ltd. (SEC No. 8-65939, 801-110136)