Clerou Romain Pierre Walsh

Item 5. Fees and Compensation

RWC charges a flat fee for services that is based solely on the assets under management.
The flat fee is 0.70% (seven-tenths of a percent) per annum. RWC may negotiate fees
based on the value of assets under management, the composition of the assets to be
managed, the expected contributions of the Client and other factors. The lowest annual
fee percentage paid by a client of RWC is 0.35%.

The value of the assets under management is based on the account statement provided
by the custodian for the day immediately preceding each quarterly period. Cash
equivalents are included in the fee calculation. The fee is payable quarterly, in advance,
on the first day of the month in which RWC first provides investment management
services.

Currently, all RWC's clients have the quarterly fee deducted directly from their account
with the custodian. However, RWC does accept check payment. Clients receive an
invoice every quarter that clearly sets forth the fee calculation.

Either party may terminate services by providing thirty days written notice of
termination to the other party. If the services are terminated before the last day of the
quarterly period, the fee paid in advance is prorated from the termination date with the
unearned portion returned to the client.

RWC is not engaged in nor does it charge fees for any other services.

Client may be charged a brokerage commission or fees by the third-party broker for
each executed trade. Currently, RWC utilizes Charles Schwab & Co., Inc. to execute
equity and bond trades. Schwab does not charge a commission or fee for most online
equity trades, but does embed a fee in the purchase price of a bond.

Schwab is also compensated by earning interest on the uninvested cash in the account.

Mutual funds including money market mutual funds and exchange traded funds
embed investment management and other fees that reduce the owner’s value. For this
and other reasons RWC does not purchase equity or bond mutual funds; although for
new accounts that have mutual fund positions RWC will retain those positions for a
period of time while individual stocks and bonds are purchased. During this period the
mutual funds are included as assets under management in the fee calculation.

Lower fees for comparable services may be available from other sources.

Firm Brochure                                    Romain Walsh Clerou
Part 2A of From ADV                              Professional Investment Management

Item 6. Performance Fees and Side-By-Side Management

RWC does not charge any account performance fees. All fees are based solely on assets
under management.

Item 7. Types of Clients

RWC provides investment supervisory and management services for individuals,
retirement accounts including pension and profit-sharing plans, and trusts.

RWC has a minimum account value requirement for prospective clients of $1,000,000
although RWC will consider the potential for growth when evaluating a prospective
client.