Ciovacco Capital Management LLC

5: Fees and Compensation

CCM will calculate management fees every 90 calendar days according to an established fee payment
cycle. CCM will instruct the custodian to deduct fees from client accounts sometime after the 90-day cycle

is complete. Investment Advisory Fees are calculated at the position level according to the following
schedule:
        Cash & Cash Equivalents:                                            20 basis points or 0.20% per year

        Diversified, Lower-Volatility ETFs:                                 50 basis points or 0.50% per year

        Non-Diversified, Higher-Volatility ETFs:                            100 basis points or 1.00% per year

Fees are calculated based on the client’s allocation to (a) cash & cash equivalents, (b) diversified, lower-
volatility ETFs, and (c) non-diversified, higher-volatility ETFs on the 90th calendar day of the billing cycle.
Since a client’s portfolio allocation is subject to change or reallocation based on market conditions, the
allocation to the three fee classifications is also subject to change. CCM's variable fee structure is designed
to produce lower fees during bearish or indecisive markets, when profit opportunities are muted in stocks.

Management fees are calculated using the table above and a snapshot of our allocations every 90 calendar
days. In bear markets, the model will tend to have a higher allocation to bonds and cash, which could
result in lower fees relative to a growth-oriented allocation that is typically held during periods marked
by strong bullish trends. This approach allows clients to remain more patient during bear markets,
knowing the model can reallocate capital to stocks once the hard evidence begins to improve, as it did in
2003, 2009, and 2016. The example below shows a hypothetical fee calculation during a bullish secular
trend, with more favorable odds for growth-oriented investments:

When the hard data tracked by the model is mixed, our allocations are adjusted as necessary, which could
produce lower quarterly/annualized management fees.

When the hard data is clearly unfavorable relative to the probability of success in the stock market, our
allocations typically shift to a defensive posture, which may produce lower quarterly/annualized fees.

The assignment of each account position or investment to one of the classifications above is solely at the
discretion of CCM. The fee schedule is non-negotiable. Investment advisory fees are prorated for periods
less than a full billing cycle.

Clients with household balances over $2,000,000 are eligible for a 5% reduction in fees based on the
client's aggregate assets managed by CCM.

Clients with household balances over $5,000,000 are eligible for a 10% reduction in fees based on the
client's aggregate assets managed by CCM.

Clients with household balances over $10,000,000 are eligible for a 15% reduction in fees based on the
client's aggregate assets managed by CCM.

Clients must sign CCM’s Portfolio Management Agreement, which provides written authorization for CCM
to instruct the third-party custodian to deduct CCM’s advisory fees. Notice of fee payments and amounts
will be provided via a line item on the client’s monthly custodian statement. CCM will also concurrently
send notification of fee amounts to the client via an invoice.

CCM Account Termination Fee: CCM does not charge an account termination fee. All third-party fees,
including custodian fees which are incurred as a result of an account termination or liquidation, are to be
paid by the client. CCM will not reimburse the client for any third-party fees at any time, unless specifically
agreed upon in advance in writing. Within five business days of signing the CCM Portfolio Management
Agreement, clients have the right to terminate without fee or penalty.

Custodian & Third-Party Fees: In addition to any investment advisory fees, the CCM client will pay all
commissions, transaction costs, or internal administration and distribution fees charged by third parties,
which are disclosed in each ETF and mutual fund prospectus which we encourage you to read. Please see

7: Types of Clients

CCM generally provides investment advice to individuals, high net worth individuals, corporations, or
other business entities. CCM clients are required to meet or exceed an initial minimum investment
threshold based on the number of accounts managed by CCM.

        Number of Accounts                        Household Investment Minimum

                1                                         $ 500,000
                2                                         $ 1,000,000
                3                                         $ 1,250,000

CCM reserves the right to waive minimum investment requirement at its sole discretion. All clients are
required to sign the CCM Portfolio Management Agreement prior to the provision of any services.