Carmel Capital Management LLC

ITEM	5	-	FEES	AND	COMPENSATION

CCM generally charges an annual advisory fee equal to 1% of the assets under management in a client
account. In some cases, when CCM accepts an initial investment that is below CCM’s usual account
minimum, CCM may charge a higher advisory fee (up to 1.5%). CCM may also charge consulting
fees for investment consulting projects; fees depend on the specific services provided.

Advisory fees are payable in advance through quarterly installments. Valuation of client accounts is
determined in accordance with market prices and industry procedures. Clients may consent to having
their fees deducted from their accounts by count custodians, or may have their fees billed to them, as
provided in the investment advisory agreement between CCM and its clients. Client is advised that it
is Client’s responsibility to verify the accuracy of the fee calculation, as the custodian will not do so on
Client’s behalf.

Clients pay the typical fees associated with an investment account, such as custodial fees, commissions
and markups charged by broker-dealers. Should client assets be invested in mutual funds, exchange
traded funds, or private funds, clients also pay their share of advisory fees and other expenses charged
by the funds. Clients should refer to Brokerage Practices, below, for more information on CCM’s

ITEM	7	-	TYPES	OF	CLIENTS

CCM provides investment advisory services to trusts, retirement accounts, primarily high net-worth
individuals, family offices, corporations, pensions and profit-sharing plans, endowments and
foundations. CCM may also have accommodation accounts for minor children of high net-worth
clients.

                ITEM	8	-	METHOD	OF	ANALYSIS,	INVESTMENT	STRATEGIES	AND	RISK	OF	LOSS

A focus on fundamental analysis and value investing are the cornerstones of Carmel Capital
Management’s investment philosophy. The firm seeks to build wealth through the purchase of high-
quality underpriced securities in a diversified portfolio. CCM utilizes “bottom-up” research to identify
and purchase investments in companies that are undervalued compared to their earnings prospects and
intrinsic value.

CCM may invest in equity securities, fixed income securities, Exchange Traded Funds (ETFs),
Exchange Traded Notes (ETNs), mutual funds, Rule 144A securities, and other securities. CCM also
recommends private fund investments to eligible clients. The mix of securities held in client portfolios
will vary depending upon CCM’s portfolio management decisions and client investment objectives.

No specific level of gain can be guaranteed, as there is always a risk of loss, including loss of principal
investments, when investing in the markets due to market volatility and company specific issues.
Some investments have limited liquidity, including those in pooled investments, which may impede
the ability to conduct purchases or sales of those investments in a timely fashion or at expected
valuations.