Commerce Street Investment Advisor LLC

Item 5. Fees and Compensation
A.      Generally

All fees are individually negotiated. Fees for advisory services may be structured as a percentage of
the client’s investible assets. Fees are negotiated based on the scope of services, the size and
complexity of the investment program, the amount of customized work and education, the level of
portfolio administration, and the frequency of meetings and travel, among other factors. With the
exception of the Funds, the Firm receives neither performance-based fees nor compensation for
execution of trades on behalf of the client portfolio. Performance-based fees applicable to the Funds
are discussed in Item 6 below.

     1. Transactions Involving a Conflict of Interest

The Firm may have a conflict of interest if it recommends a product or investment for which a third-
party provider otherwise compensates it. The Firm always discloses this potential conflict of interest
to the client when it occurs.

B.      Payment of Fees

The Firm provides certain services to its clients, which generally include the origination and
evaluation of investment opportunities, the structuring of investment transactions, investment
recommendations, investment monitoring, advice on investment realizations, and the performance of
certain administrative services. In return for providing such services, the Firm is entitled to receive a
management fee based on committed capital in accordance with the terms of the applicable offering
documents for each Fund. For the Funds, management fees typically range from 1% to 2% and are

calculated and paid quarterly in advance, effective at the beginning of each calendar quarter.
Management fee rates differ amongst partners based on investor class and commitment amount.
Management fees are prorated for any period shorter than a full quarter. For CPE I, the Firm is paid a
quarterly service fee.

For CSIA’s fee-only investment management fiduciary and non-fiduciary services, fees typically
range from 10 to 100 basis points (i.e., .10%-1.0%) and are negotiated with the ERISA plan sponsor.
Similar services offered to SMAs are negotiated on an individual basis and may range from 10 to 200
basis points (i.e., .10%-2.0%). These fees are billed in arrears at the end of each calendar quarter based
upon the market value of the client’s account at the end of the previous quarter or an average market
value of the end-of-month values from the three previous months.

C.      Additional Fees and Expenses

In addition to amounts noted above and in Item 6, the Funds pay operating expenses such as
professional fees and administrative costs, including any expense for services provided by the Firm
or any of its affiliates with respect to accounting and other services performed in connection with the
Funds’ annual audit, legal compliance, financial reporting, tax return preparation, and distribution of
reports. Additionally, the Funds paid organizational expenses, up to a certain threshold, for costs and
expenses pertaining to the offering and sale of partner interests to prospective investors and the
organization of the Funds and the General Partners. A full description of additional fees and expenses
is disclosed to clients in the applicable offering documents.

     1. Service Pricing Promotions and Discounts

The Firm may offer discounts and/or promotional pricing on any of the services noted above to select
clients, plans, and/or participants.

     2. Other Fees and Expenses

All fees clients pay us for investment advisory services are separate and distinct from the fees and
expenses charged by mutual funds and/or ETFs to their shareholders. These fees and expenses are
described in each fund’s prospectus. These fees will generally include a management fee and other
fund expenses. To the extent possible, we recommend institutional class mutual funds and other funds
that do not charge 12b-1 or distribution fees.

     3. Potential Conflicts of Interest

CSIA provides independent, fee-only investment management services, both fiduciary and non-
fiduciary, as defined under ERISA, for qualified retirement plans. With the exception of Commerce
Street Capital, LLC, a registered broker-dealer disclosed in Item 10 of this brochure, we have no
financial affiliation with any other brokerage firm or mutual fund company and do not have our own
proprietary mutual funds. CSIA will not receive commissions or other forms of compensation for
client account transactions from anyone. Clients may impose reasonable restrictions on investing in

certain securities, types of securities, or industry sectors. Our investment recommendations are not
limited to any specific product or service offered by any particular mutual fund or insurance company.
Because some types of investments involve additional degrees of risk, they will only be
implemented/recommended when consistent with the client’s stated investment objectives, risk
tolerance, liquidity, and suitability.

     4. Service Termination Provisions and Refund of Fees Paid

Clients may terminate their relationship with CSIA at any time upon 30-days written notice. However,
please note that any client wishing to cancel a service as of a date prior to the end of the previously
selected service period, and wishing to receive a refund, to the extent applicable, for any unused
portion of that service period, must cancel by written or email notice.
D.      Fees Paid in Advance
Management fees shall be calculated and payable to the Firm quarterly in advance and are prorated
for partial periods.
E.      Additional Compensation of Supervised Persons

No supervised person accepts compensation for the sale of securities or other investment products.

Item 7. Types of Clients

The Firm provides advisory services to investment vehicles as described in Item 4.B. The minimum
capital commitment for an Investor is outlined in the applicable offering documents. Clients include
accredited investors, federally insured depository institutions (banks or credit unions), ERISA plan
sponsors, plan participants, and individual customers wishing to obtain advice regarding their
employer-sponsored retirement plans. Risk-based model portfolio concepts should not be construed
as any guarantee of efficiency in expected returns as compared to portfolio risk. CSIA applies a variety
of criteria in choosing funds for each asset class, including historical returns, fee ratios, management
tenure, and several other criteria, the application of which may cause a recommended portfolio to be
theoretically less efficient than it may have been had other fund recommendations been made.
Additionally, CSIA’s ability to match funds to asset classes for any given plan is limited, potentially
significantly, due to limitations in the number and/or types of funds offered in any particular plan.

Please note that portfolio recommendations provided by CSIA to a participant of a particular 401(k)
plan do not take into account investments and other assets held by the participant outside of that plan.