Capco Asset Management LLC

Item 5         Fees and Compensation
Fees for separate accounts are 1.5% of assets under management per year, billed and deducted from assets,
one twelfth per month in arrears.

Fees for the partnership will be, at each limited partner's election, either (1) 1.5% of assets under
management, per year, billed and deducted from assets, approximately one-twelfth per month in arrears, or
(2) an incentive reallocation of 20% of that partner's profits subject to a high water mark, determined
monthly, also deducted from assets. The “approximately one-twelfth” calculation is based on the actual
numbers of days in a month divided by the days in the year, so the exact fraction varies slightly.

Capco does not negotiate fees or give discounts, but in special circumstances may, in its discretion, choose
to charge clients no fee at all. Capco does have one unique relationship which receives a reduced fee; this
is not a negotiated discount, but rather reflects the wish of one of the owners that a particular client’s fees
be reduced by his percentage ownership of the firm, and his profit sharing being reduced accordingly.

For Separate Accounts, a client may terminate the investment advisory contract at any time in writing.
Fees will be pro-rated for the time the account was managed.

For the partnership, a limited partner may withdraw funds at any quarter end upon 30 days prior written
notice. Withdrawals may be made at other times at the discretion of the General Partner. An Amendment
to the Partnership to formalize the General Partner’s discretion to allow more frequent withdrawals and/ or
shorter notice was approved by the Limited Partners.

Clients will also pay other expenses, including trading commissions (see Item 12), and in the partnership
will bear certain expenses related to the existence and operation of the partnership. Beginning in 2020,
Capco began voluntarily absorbing certain expenses related to the existence of the partnership, a practice it
is free to discontinue at any time. To the extent that assets are invested in other vehicles like money
market funds, mutual funds, ETFs or other entities, they will bear any fees and costs associated with those
entities. The account custodian may also charge certain fees from time to time.

Capco does not require clients to pay fees in advance, nor is this presently offered as an option.

Neither Capco nor its employees are compensated by third parties (such as mutual funds) for selling their
investment products. Nor do they accept soft dollars from brokers.

Item 7          Types of Clients
Capco’s clients include individuals, partnerships and trusts, including other investment partnerships, and
charitable entities. Other types of entities would also be accepted if they were otherwise a good fit for our
approach. The minimum investment relationship is now $500,000, but Capco has the discretion to require
a higher or lower minimum. There are a number of subjective factors that Capco also takes into account in
determining whether to accept a relationship, such as the relationship with the potential client, the
complexity of the account, or other matters.

Capco manages IRA accounts. In some instances, Capco has discussed with clients (a) rolling assets into
an IRA to be managed by Capco, from an employer’s retirement plan or other qualified retirement account,
and (b) transferring assets from an existing IRA not managed by Capco, into one that is managed by
Capco. This creates a conflict of interest because Capco has an interest in seeing such assets moved from
an account that pays it no fees, to an account that does pay it fees, and this may affect our
recommendations, rather than solely the best interests of the client (this conflict is also present with respect
to non-retirement accounts). The existing retirement plan may have fees that are lower than Capco’s, may
offer more or different investment options, may offer a different mix of risks and returns, may be subject to
different rules or laws than an IRA (such as 401k loans, liability protection or later dates for mandatory
withdrawal), and may offer other services or options Capco does not. To mitigate this risk, we refrain from
making such recommendations, or make recommendations that are in the clients’ best interests. We may
also choose not to accept a roll-over or transfer. To the extent we do make a recommendation, we must
carefully consider these and other factors, and your best interests.

When we provide investment advice to you regarding your retirement plan account or individual retirement
account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act
and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way
we make money creates some conflicts with your interests, so we operate under a special rule that requires
us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions,
we must:
        • Meet a professional standard of care for investment recommendations (give prudent advice);
        • Put your financial interests ahead of ours when making recommendations (give loyal advice);
        • Avoid misleading statements about conflicts of interest, fees, and investments;
        • Follow policies and procedures designed to ensure that we give advice that is in your best interest;

         • Charge no more than is reasonable for our services; and
         • Give you basic information about conflicts of interest.