Connecticut Capital Management Group LLC

Item 5: Fees and Compensation

A. Fee Schedule

    Portfolio Management Fees

    Portfolio Management Fees are typically structured on a tiered basis, and are collected
    directly from the Assets Under Management (AUM) per the schedule below:

          Total Assets Under Management             Annual Fees
          $0 - $1,000,000                           1.20%

          $1,000,001 - $5,000,000                   0.95%

          $5,000,001 - $25,000,000                  0.70%

          $25,000,001 – And Up                      0.45%

    In the event CCMG utilizes third party money managers for portfolio management
    services, there is an additional 0.15% fee on all assets under third party management,
    which are collected directly from managed assets, quarterly in arrears.

    CCMG calculates AUM based fees on the quarter end value, after taking into account
    deposits and withdrawals during the period. Asset-based portfolio management fees are
    withdrawn directly from the client's accounts, with client's written authorization,

quarterly in arrears. CCMG does not value assets and bases calculations on the values
reported by an independent custodian.

For clients with less than $1,000,000 of AUM, CCMG may provide Portfolio Management
Services on a Fixed Fee basis in lieu of an AUM based fee. The Fixed Fee schedule is $3,000
paid quarterly, in arrears, billed to the client. When applicable, this fee is prorated based
on the number of days in the quarter in which the Investment Advisory Contract was in
force.

Fees may be negotiable and the final fee schedule will be memorialized in the client’s
advisory agreement. Clients may terminate the agreement without penalty for a full
refund of CCMG’s fees within five business days of signing the Investment Advisory
Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately
upon written notice.

Pension Consulting Services Fees

      Total Assets Under Management           Annual Fee
      $0 - $1,000,000                         1.50%

      $1,000,001 - $5,000,000                 1.00%

      $5,000,001 - $25,000,000                0.75%

      $25,000,001 – And Up                    0.50%

Except where otherwise noted in CCMG’s Pension Consulting Agreement, CCMG uses
the value of the account as of the last business day of the billing period, after taking into
account deposits and withdrawals, for purposes of determining the market value of the
assets upon which the advisory fee is based.

These fees may be negotiable and the final fee schedule will be memorialized in the client’s
advisory agreement. Clients may terminate the agreement without penalty for a full
refund of CCMG's fees within five business days of signing the Investment Advisory
Contract. Thereafter, clients may terminate the pension consulting agreement
immediately upon written notice.

Financial Planning Fees

Financial Planning fees are generally included in the Portfolio Management Fee. If no
assets are managed by CCMG, the negotiated fixed rate for creating client financial plans
is between $1,000 and $20,000. Clients may terminate the agreement without penalty, for
full refund of CCMG’s fees, within five business days of signing the Financial Planning
Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally
upon written notice.

B. Payment of Fees

  Payment of Portfolio Management Fees

  AUM fees are withdrawn directly from the client's accounts, with client's written
  authorization, quarterly in arrears. Fixed fees are billed to the client, quarterly in arrears.

  Payment of Pension Consulting Services Fees

  Asset-based pension consulting fees are withdrawn directly from the client's accounts, with
  client's written authorization, quarterly in arrears.

   Payment of Financial Planning Fees

   Financial planning fees are paid via check, 50% in advance, but never more than six months
   in advance, with the remainder due upon presentation of the plan.

C. Client Responsibility For Third Party Fees

  Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage
  fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the
  fees and expenses charged by CCMG. Please see Item 12 of this brochure regarding broker-
  dealer/custodian.

D. Prepayment of Fees

  CCMG collects certain fees in advance and certain fees in arrears, as indicated above.
  Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis
  and returned within thirty days to the client via check, or return deposit back to the client’s
  account.

  Fixed fees that are collected in advance will be refunded based on the prorated amount of
  work completed at the point of termination.

E. Outside Compensation For the Sale of Securities to Clients

  Neither CCMG nor its supervised persons accept any compensation for the sale of
  investment products, including asset-based sales charges or service fees from the sale of
  mutual funds.

Item 7: Types of Clients

CCMG generally provides advisory services to the following types of clients:

           ❖   Individuals
           ❖   High-Net-Worth Individuals
           ❖   Pension and Profit Sharing Plans
           ❖   Foundations/Non-Profit Organizations

CCMG generally does not require an account minimum.

Each client will be required to execute an advisory agreement with CCMG and to establish an
account with a third-party qualified custodian in order to become a client of CCMG.