Christy Capital Management Inc

Item 5: Fees and Compensation
A. Advisory Fees and Compensation
Managed Account Programs
Fees for services provided through the Subadvisor Program are charged based on a
percentage of assets under management and are typically paid quarterly, in arrears, based
upon the average daily balance of the Assets on the last business day of the previous
quarter. No increase in the annual fee percentage shall be effective without prior written
notification to and consent of the client.

The services under the Subadvisor Program continue in effect until terminated by Advisor
or client. See Item 5.D. below for an explanation of how CCM handles terminations of the
client relationship.

Fees for investment advisory services are negotiable based upon the type of client, the
complexity of the client's situation, the composition of the client's account (e.g., equities
versus mutual funds or ETFs), the relationship of the client with the investment adviser
representative, the total amount of assets under management for the client, and the
third-party manager selected.

The total annual fee for asset management services in the Subadvisor Program will be no
more than 1.8% of the account value, calculated as described above. Of this fee, CCM
will receive up to 1.5%, with the Subadvisor receiving the remainder.

The specific annual fee to be charged will be specified in the client’s agreement with
CCM. Pursuant to the authority granted by the client in the agreements with CCM, this
asset management fee will be deducted directly from the client’s account and paid
directly to the subadvisor and CCM. Clients must authorize the qualified custodian(s) of
their account to deduct fees from their account and to pay such fees directly to the third-
party manager and CCM. Clients should review account statements received from the
qualified custodian(s) and verify that appropriate investment advisory fees are being
deducted. The qualified custodian(s) will not verify the accuracy of the investment
advisory fees deducted.

CCM believes that its fee is reasonable in relation to: (1) services provided and (2) the
fees charged by other investment advisers offering similar services/programs. However,
our fee may be higher than that charged by other investment advisers offering similar
services/programs.

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CCM’s fees are exclusive of (meaning they do not include) transaction fees, broker
commissions, and other related expenses incurred in connection with servicing client
accounts or otherwise arising out of transacting business for or on behalf of clients. Also,
the qualified custodian which holds your account may charge a separate commission,
ticket charge or fee for executing securities transaction. CCM does not receive any
portion of such commissions, ticket charges or custodial fees from the qualified
custodian or otherwise.

Other third party charges the client may incur in connection with investments made
through the account include ETF sales loads and management fees, sales charges and
management fees for alternative investments, mutual fund sales loads, periodic mutual
fund fees (e.g. 12b-1 trails) and surrender charges, IRA and qualified retirement plan
fees. Management fees charged are separate and distinct from the fees and expenses
charged by investment company securities that may be recommended to you. A
description of these fees and expenses is available in the prospectus for each
investment company security.

As discussed in Item 4.A. above, CCM is in a subadvisory relationship with Retirement
Management Services, Inc. (“RMS”) under which CCM referred clients to RMS based upon an
evaluation of the client’s circumstances and objectives. In those relationships, RMS
pays CCM a portion of the program fee which is a percentage of the fee RMS receives
from the client.

A complete description of any third-party subadvisor’s services, fee schedules and
account minimums were disclosed in the subadvisor’s disclosure brochure which is
provided to the client prior to or at the time the account was established.

The actual fee charged varies depending on the subadvisor third-party money manager.
All fees are calculated and collected by the subadvisor, who is responsible for delivering
CCM’s portion of the fee. The referral fee paid to CCM does not increase the fee paid by
the client to the subadvisor. Under this program, clients may incur additional charges
including mutual fund sales loads, 12b-1 fees and surrender charges, and IRA and
qualified retirement plan fees

CCM has a conflict of interest in only recommending those subadvisors that have agreed
to pay a portion of CCM’s advisory fee to CCM and that have satisfied the conditions of
CCM’s due diligence review. There may be other subadvisors suitable for clients that may
be more or less costly. The portion of the advisory fee paid to CCM may be negotiated by
the investor and their advisor. No guarantees can be made that your financial goals or
objectives will be achieved. Further, no guarantee of performance can be offered.

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Where an ERISA retirement plan has engaged CCM to provide retirement plan services,
we will provide non-discretionary investment advisory services to the sponsor as
outlined in ERISA §3(21), as well as plan participant education. In general, we divide the
ERISA §3(21) fiduciary responsibilities with another registered investment advisor, such
as PHD Retirement Solutions, with whom the client will have a separate contractual
relationship. In such cases, we and the other registered investment advisor will split the
§3(21) fee and responsibilities.

B. Payment of Fees
Advisory fees are withdrawn directly from the client’s accounts by the subadvisor, with
the client’s written authorization. Fees are deducted quarterly by the subadvisor
...

Item 7: Types of Clients
CCM generally provides investment advice to the following types of clients:

     •   Individuals
     •   High-Net-Worth Individuals
     •   Trusts, Estates, or Charitable Organizations
     •   Pension and other Retirement Plans

There are no minimum investment amounts or conditions required for establishing an
account managed by CCM.