C C Dunnavan & Co Inc

Item 5: Fees and Compensation

A. Fee Schedule

Investment Supervisory Services Fees

          Total Assets Under Management                  Annual Fee

         All Assets Under Management                       1.00%

These fees are negotiable and the final fee schedule is attached in the Investment Advisory
Contract. Fees are paid quarterly in advance, and clients may terminate their contracts
with written notice. Refunds are given on a prorated basis, based on the number of days
remaining in a quarter at the point of termination. Clients may terminate their contracts
without penalty, for full refund, within 5 business days of signing the advisory contract.
Advisory fees are withdrawn directly from the client’s accounts with client written
authorization.

B. Payment of Fees

Payment of Investment Supervisory Fees

Advisory fees are withdrawn directly from the client’s accounts with client written
authorization. Fees are paid quarterly in advance.

Advisory fees may also be invoiced and billed directly to the client with payments due on
the first of the month after quarter end. Clients may select the method in which they are
billed.

C. Clients Are Responsible For Third Party Fees

Clients are responsible for the payment of all third party fees (i.e. custodian fees, mutual
fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and
expenses charged by CCD.             Please see Item 12 of this brochure regarding
broker/custodian.

D. Prepayment of Fees

CCD collects fees in advance. Fees that are collected in advance will be refunded based on
the prorated amount of work completed at the point of termination and the total days
during the billing period. Fees will be returned within fourteen days to the client via
check.

E. Outside Compensation For the Sale of Securities to Clients

       Neither CCD nor its supervised persons accept any compensation for the sale of securities
       or other investment products, including asset-based sales charges or services fees from
       the sale of mutual funds.

Item 7: Types of Clients

CCD generally provides management supervisory services to the following types of clients:

            Individuals
            High-Net-Worth Individuals
            Pension and Profit Sharing Plans
            Trusts, Estates, or Charitable Organizations
            Corporations or Business Entities

Minimum Account Size

There is an account minimum, $500,000, which may be waived by the investment advisor, based
on the needs of the client and the complexity of the situation.