CE Investment Management LLC

Item 5—Fees and Compensation

 Advisory Fees

 As mentioned previously, CEIM provides services solely to affiliates under asset-based fee
 schedules.

 Asset-based fees are calculated based on the value of a client’s portfolio at periodic measurement
 dates or over specified periods of time. The actual fee to be paid is negotiated with each client. In
 addition, as part of its investment management services, CEIM may recommend investment with
 outside third-party managers who provide a specialized investment service. Funds allocated to these
 managers will not be charged any additional fees for this service.

 Payment of Fees

 All clients are invoiced, and fees paid by the client directly. Asset-based fees are typically payable
 either monthly or quarterly in arrears.

 We do not require or solicit clients to pay advisory fees in advance. If a client were to pay advisory
 fees in advance and the client’s advisory contract were to terminate before the end of a billing period,
 we would refund any unearned, prepaid fees on a pro rata basis.

 Other Amounts Payable by Clients

 Advisory fees are the only amounts payable by advisory clients to CEIM. Clients are generally
 responsible for other fees and expenses related to their accounts, including custodial fees, brokerage

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 fees and other transactions costs. (See Item 12 below for a discussion of our policies regarding the
 selection of broker-dealers.) Investors in funds we manage typically bear additional expenses
 associated with the fund structures, such as administrator and other third-party service provider fees.

 Other Compensation

 Neither CEIM, nor our employees or supervised persons receive any compensation directly related to
 the sale of securities or other investment products. Certain components of the compensation of sales
 employees are determined based on the successful sales of our and our affiliates advisory services
 or interests in funds that we manage. Any such compensation would be payable by CEIM and not our
 clients or investors in the funds.

Item 7—Types of Clients

 As mentioned previously, at the time of this filing, we provide investment advisory services to the
 following affiliated companies:

    o      American Fidelity Assurance Company (“AFA”),
    o      American Fidelity International, Ltd. (“AFIL”),
    o      American Public Life Insurance Company (“APL”),
    o      American Fidelity Foundation (“AFF”),
    o      American Fidelity Corporation (“AFC”), and
    o      Cameron Family Foundation (“CFF”).

 Minimum account sizes vary by investment strategy. We may waive these minimums at our
 discretion.

 Our investment management or similar agreements with clients, which include investment guidelines,
 are negotiated to incorporate mutually acceptable terms. Under these agreements, clients may
 impose limitations on our investment discretion, such as restrictions regarding the investment in
 certain securities or types of securities.

 In the future, CEIM may also provide investment advisory services to non-affiliates.