Concord Investment Counsel

Item 5:      Fees and Compensation
MACM offers clients two alternatives for paying MACM’s investment management fee. MACM’s fee can
be based upon assets under management or can be based upon the profits generated.

   A.) Asset-Based Management Fee alternative:
       Clients selecting our asset-based management fee alternative will be charged a management fee
       based on the value of the Client's account. The annual fee is normally 1.0% of assets for equity-
       oriented accounts and 0.5% of assets for fixed income accounts. The fee is negotiable and may
       be higher for accounts below our minimum.
   B.) Performance-based management fee alternative:
       In addition to our asset-based management fee alternative, registrant also offers Clients a
       performance-based management fee alternative. With our performance based fee, Clients only
       pay a management fee when their account earns money. The fee is 15% of the managed
       account’s profits. (see details noted below in Item 6).
   C.) Advisory Fees:
       Registrant’s advisory fees will be deducted from their custodial account. Both Registrant's
       Investment Advisory Agreement and the custodial/ clearing agreement may authorize the
       custodian to debit the account for the amount of the Registrant's investment advisory fee and
       to directly remit that management fee to the Registrant in compliance with regulatory
       procedures. In the limited event that the Registrant bills the Client directly. Payment is due
       upon receipt of the Registrant’s invoice. The Registrant shall deduct fees and/or bill Clients
       quarterly in advance, based upon the market value of the assets on the last business day of the
       previous quarter.
   D.) Transaction Charges:
       In addition to our advisory fees, Clients are also responsible for the transaction charges imposed
       by the brokerage firm in which we effect transactions for the Client's account(s).
   E.) Payment of fees:
       Registrant's asset based annual investment advisory fee shall be prorated and paid quarterly, in
       advance, based upon the market value of the assets on the last business day of the previous
       quarter. The Registrant generally requires a minimum asset base of $500,000.00 for investment
       advisory services. The Registrant, in its sole discretion, may charge a lower investment
       management fee and/or waive or reduce its minimum asset requirement based upon certain
       criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar
       amount of assets to be managed, related accounts, account composition, negotiations with
       Client, etc.). The Investment Advisory Agreement between the Registrant and the Client will
       continue in effect until terminated by either party by written notice in accordance with the
       terms of the Investment Advisory Agreement. Upon termination, the Registrant shall refund the
       pro-rated portion of the advanced advisory fee paid based upon the number of days remaining
       in the billing quarter.
   F.) MACM not a Broker/dealer:

      Neither the Registrant, nor its representatives accept compensation from the sale of securities
      or other investment products.

Item 7:     Types of Clients
      Registrant provides advisory services to individuals, pension and profit sharing plans, business
      entities, estates, and charitable organizations. Nearly all accounts that can be opened at a
      brokerage firm can be managed by registrant.