Compak Asset Management

Fees and Compensation (Item 5)
This section of the brochure describes how we are compensated for the services we offer.

Compensation Methodology and Rates
Assets Under Management
For our investment supervisory services, we charge our clients an account management fee
and an account maintenance fee. All fees are charged quarterly in advance, based on the
custodian’s value of securities and account data sent to Compak Asset Management on the
last business day of the quarter. Your specific annual fee arrangement will be described in
the written Investment Advisory Agreement entered into between you and Compak Asset
Management. Investment advisory fees and account maintenance fees charged by us are
negotiable at our sole discretion. All clients do not pay the same fee. A lower fee for a
comparable service may be available from other sources. Compak and some of its
Investment Advisor Representatives receive compensation based on the level of assets
placed with them. When we charge asset-based fees, the more assets we manage, the more
you’ll pay in management fees. We therefore have financial incentive to encourage you to
increase the amount of assets we manage for you.
Account Maintenance Fee
You will be charged an Account Maintenance Fee of $45 per calendar quarter for each of
your accounts under our management with a value greater than $10,000. The Account
Maintenance Fee is assessed in advance at the beginning of each calendar quarter. We may
waive this fee at our discretion.

We will collect management and account maintenance fee by debiting the fee directly from
your account. In the event that the Investment Management Agreement is terminated
during the calendar quarter, we will provide a pro rata refund of the fee to you. We reserve
the right, in our sole judgment, to redeem mutual funds or sell securities using our
discretionary authority in order to collect our fees.

Account Management Fee
You will be assessed a tiered Account Management Fee in advance for the forthcoming
calendar quarter based upon the value of your account assets under management. A matrix
of our fee calculation follows:

            Market Value of Account Assets                Quarterly Asset-Based Fees
                    $0 to $500,000                                   0.50%
                $500,001 to $1,000,000                              0.375%
               $1,000,001 to $2,500,000                              0.25%
               $2,500,001 to $5,000,000                            0.1875%
                 $5,000,001 and above                                0.15%

As an example, a Standard Account with $3,000,000 under management at the end of a
calendar quarter will be charged an Account Management Fee of 0.50% of the first
$500,000 under management, 0.375% of the next $500,000 under management, 0.25% of
the next $1,500,000 under management and 0.1875% of the final $500,000 under
management. Our fees are negotiable, and all clients do not pay the same fee rates.
Compak may offer reduced management fees at its discretion.

Clients that are referred to us through Fidelity Wealth Advisor Solutions® (the “WAS
Program”) are billed using a different fee schedule than the one shown above. Refer to Item
14 of this document for a full description of the WAS Program. WAS Program clients will
pay a quarterly rate of 0.25% on all assets below $2,500,000. Accounts valued at greater
than $2,500,000 will use the fee schedule shown above or as agreed to in the client’s
written agreement with us.

If you make additional deposits or withdrawals from your account(s) during the quarter,
Compak Asset Management may, but is not obligated to, prorate the Account Management
Fee with respect to such deposits or withdrawals.

Because advisory fees are billed quarterly in advance, clients should be aware that fees will
be deducted before services for the billing period are fully performed. Upon termination of
the advisory agreement, any prepaid but unearned fees will be refunded on a prorated
basis. If the management agreement does not span the entire quarterly billing period, the
fee will be pro-rated based on the number of days the account is open during the billing
period. Your account custodian will send you account statements, at least quarterly,
showing all disbursements for your account including the amount of the advisory fee, if
deducted directly from the account. It is the shared responsibility of Compak Asset
Management and you to verify the accuracy of the fee calculation as the account custodian
will not determine whether the fee has been properly calculated. See Brokerage Practices
(Item 12) in this brochure for more information about your account custodian(s).

Either you or we may terminate the Investment Advisory Agreement with thirty (30) days
written notice. Any unearned asset management fees collected in advance of services being

performed will be returned to you on a pro rata basis. Compak may waive the 30 days
notification requirements of the client at its discretion.

Structured notes or 3rd party alternative investments recommended by Compak will not
be charged commissions by Compak. These notes will be included in the Market Value of
Account Assets and your account will be assessed the management fee discussed under
“Account Management Fee”. Compak or its representatives do not receive any
compensation for structured notes or alternative investment transactions other than the
account management fee. Advisory fees charged by 3rd party mangers are separate and
apart from Compak’s management fee. Clients may be required to sign an agreement
directly with the recommended 3rd party alternative investment manager(s). In such cases
Clients may be able to terminate their advisory relationship with the 3rd party manager
according to the terms of their agreement with the 3rd party manager. Clients should
review each 3rd party manager's alternative investment subscription documents for
...

Types of Clients (Item 7)
This section of the brochure describes who we generally provide our services to.

We generally offer our investment supervisory services to clients who place assets with a
value of at least $150,000 under our management. We believe that $150,000 is the
minimum account value that can best take advantage of the full range of our analytical
strategies. At our discretion we may accept or retain accounts smaller than the stated
minimum.

Individuals
Compak Asset Management provides advisory services to a variety of types of clients
including individuals, trusts, individual’s retirement plan accounts, and retirement plan
trustees.

Retirement Plans
Compak Asset Management provides advisory services to 401(k), profit sharing, and
defined benefit plans. These services include recommendations to the plan which are then
approved by the retirement plan sponsor. In some cases, we will serve as a discretionary
advisor to the plan or plan participants. You are encouraged to ask your plan sponsor what
services we are providing the plan.

Methods of Analysis, Investment Strategies, and Risk of Loss