Colomb Investment Management Company LLC

Item 5 – Fees and Compensation

Investment Management Services

As mentioned above, investment management services may be provided to clients by
CIMCO, or may be provided jointly by CIMCO and third party managers in the form of an
ongoing “co-advisory” arrangement.

Related to fees, clients are generally charged based on the amount of assets under
management. The total fee charged to clients, on an annual basis, may range between 0% -
2% of total assets under management depending on whether a third party manager is used,
the scope of the engagement, etc. (1.5% maximum fee for internally managed accounts). In
some instances, fees may be negotiable. Payment is generally due quarterly in advance
based on the value of the account at the beginning of the applicable period (i.e. the end of
the prior period), and is generally deducted from the account (although may be directly
billed in some cases). If terminated, a client will receive a prorated refund of any prepaid
fees which are unearned and paid in advance based on the number of days of service
provided during the partial period. For fees paid in arrears, fees will be charged for partial
periods on a prorated basis based on the number of days of service provided during the
partial period.

When services are provided directly by CIMCO, CIMCO will receive a fee directly from the
client. Fees are generally negotiable and may vary by client. All relevant fees will be
detailed in, and governed by, the client’s respective investment management agreement.
When services are provided through a third party manager jointly with CIMCO in the form
of a co-advisory arrangement, CIMCO will receive from the third party manager a
percentage of the overall fee paid by the client. Fees may vary by client and all relevant
fees will be detailed in and governed by the client’s respective investment management
agreement or three-party investment management agreement and further disclosed in
other relevant disclosure documents of the advisers.

Fees paid to CIMCO and third party managers are separate and unrelated to any fees or
expenses assessed by mutual funds, exchange traded funds, brokers, custodians etc. The
firm makes no guarantee related to the competitiveness of investment management fees or
outside costs and acknowledges that clients may be able to find comparable services from
other sources at a lower cost or fee. See Item 12 below for additional information on

Item 7 – Types of Clients

CIMCO provides services to individuals, pension and profit sharing plans, trusts, estates
and small businesses.

The minimum investment required by an individual investor client is generally $100,000.
The minimum plan size required for a retirement plan consulting engagement is also
$100,000. Engagements below these minimums may be negotiable and accepted on an
individual basis at the firm’s discretion. We may from time to time establish, modify and
waive account or investment minimums for different investment products and/or services.

In addition, third party investment advisors which we use may have their own minimum
investment requirements.