Cardenas Asset Management LLC

Item 5:        Fees and Compensation

       The specific manner in which fees are charged by CAM is established in a client’s written
       agreement with the Firm. CAM will generally bill its fees on a quarterly basis in arrears. Pursuant
       to its agreement with Client, CAM will instruct the qualifying custodian to directly debited the fees
       from the Client’s account. CAM will require its qualified custodian, pursuant to a written contract,
       to provide periodic account statements directly to its clients on no less than a quarterly basis and
       otherwise comply with the federal requirements for an investment adviser who has custody by virtue
       of its ability to automatically debit its clients’ accounts for the advisory fee. Management fees shall
       be prorated for each capital contribution and withdrawal made during the applicable calendar
       quarter (with the exception of de minimis contributions and withdrawals). Accounts initiated or
       terminated during a calendar quarter will be charged a prorated fee.

       CAM’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and
       expenses which shall be incurred by the client. Clients may incur certain charges imposed by
       custodians, brokers, third party investment and other third parties such as fees charged by
       managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer
       and electronic fund fees, and other fees and taxes on brokerage accounts and securities
       transactions. Mutual funds and exchange traded funds also charge internal management fees,
       which are disclosed in a fund’s prospectus. This may include certain fees paid out of mutual fund
       assets (sometimes referred to as “12b-1 fees”) to cover the costs of advertising, marketing,

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       distribution and shareholder services fees. CAM and its advisers continue to strive to select the
       mutual fund share class that is most appropriate for their clients, which may include mutual funds
       that pay a 12b-1 fee to the broker-dealer utilized to execute the securities transaction. CAM does
       not share in any of the revenue provided by the 12b-1 fee. On occasion, the selection of a specific
       share class may be deemed to be inappropriate for the client because of the payment of the 12b-
       1 fee to the broker-dealer. If that is the case, the clearing firm generally will have discretion to
       transfer the mutual fund shares to a share class that is more appropriate for the clients. Such
       charges, fees and commissions are generally established by the third-party service provider (and
       not CAM) and are generally exclusive of. and in addition to. CAM’s fee. As stated previously, CAM
       does not receive any portion of these commissions, fees, and costs.

       All securities in an account are coded as an equity security, fixed income security or cash. As of
       the date of this brochure, the following list represents the annual fee assessed on accounts with
       the following securities in their portfolio:

          Equities, Stock Mutual Funds, Balanced Mutual Funds                              .65%
          Fixed Income, Preferred Stock, Certificates of Deposit, Income Funds             .30%
          Cash, Money Market Funds                                                         .15%

       Since CAM has determined that its fees are competitive in the marketplace, it has determined that
       its management fees are non-negotiable in order to treat each client equitably.

       CAM will not charge Clients for requested duplicate statements, tax reports or historical buy/sell
       information for litigation claims or as needed for tax preparation that are a part of CAM’s records;
       however, statements that are requested directly from the Custodian may be subject to the
       custodian’s fees for duplicate statements.

       Clients are assessed a minimum annual fee of $100 per client. This minimum fee may be waived
       at CAM’s sole discretion.

       Clients have the right to cancel the advisory contract after providing notice to CAM at least five (5)
       days in advance of any cancellation notice. Since fees are paid in arrears, clients remain obligated
       to pay for any services and expenses that may incurred prior to the official cancellation.

       Please see Item 12 for further description of the factors that CAM considers in selecting or
       recommending broker-dealers for client transactions and determining the reasonableness of their
       compensation (e.g., commissions).

Item 7:        Types of Clients

       CAM provides portfolio management services to individuals, high net worth individuals, charitable
       institutions, trusts, estates, corporations and business entities, including Simplified Employee
       Pension Plans (“SEPs”) plans. In order for clients to participate in CAM programs, account balance
       minimums may be imposed based on the investment program selected. CAM reserves the right to

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       amend or waive these requirements at any time. Failure to maintain certain account minimums
       may result in the termination of the account and the investment advisory agreement.