Costello Asset Management Inc

Fees and Compensation
      Description
              COSTELLO ASSET MANAGEMENT, INC. bases its fees on a percentage of assets under
              management. Fees are negotiable.

      Other Fees
             Custodians may charge transaction fees on purchases or sales of certain mutual funds and
             exchange-traded funds. These transaction charges are usually small and incidental to the purchase
             or sale of a security.

               COSTELLO ASSET MANAGEMENT, INC., in its sole discretion, may lower its annual
               investment management fee based upon certain criteria (e.g., historical relationship, type of assets,
               anticipated future earnings capacity or additional new business from client, dollar amounts of
               assets to be managed, related accounts, account composition, negotiations with clients, etc.).
               Investment Advisory Agreement fees may be adjusted for complexity of individual situations. The
               formula may be based upon number of accounts, gross assets and /or other financial
               considerations.

                                  COSTELLO ASSET MANAGEMENT, INC.

      Expense Ratios
             Mutual funds and ETF’s generally charge a management fee for their services as investment
             managers. The management fee is called an expense ratio. For example, an expense ratio of 0.50
             means that the mutual fund company charges 0.5% for their services. These fees are in addition to
             the investment advisory fees paid by you to COSTELLO ASSET MANAGEMENT, INC.

      Past Due Account and Termination of Agreement
              COSTELLO ASSET MANAGEMENT, INC. reserves the right to stop work on any investment
              advisory account that is more than 45 days overdue. In addition, COSTELLO ASSET
              MANAGEMENT, INC. reserves the right to terminate any investment advisory engagement
              where a client has willfully concealed or has refused to provide pertinent information about
              financial situations when necessary and appropriate, in COSTELLO ASSET MANAGEMENT,
              INC.’s judgment, to providing proper investment advice.

Types of Clients
      Descriptions
              COSTELLO ASSET MANAGEMENT, INC. generally provides investment advice to individuals,
              non-profits, trusts, estates and other business entities.

               Client relationships vary in scope and length of service.

      Account Minimums
             The minimum account size is $100,000 of assets under management. There is no minimum fee.

               Accounts of less than $100,000 may be set up when the client and the advisor anticipate the client
               will add additional funds to the accounts bringing the total to $100,000 within a reasonable time.
               Other exceptions will apply to the employees of COSTELLO ASSET MANAGEMENT, INC.
               and their relatives, or relatives of existing clients.

Methods of Analysis, Investment Strategies and Risk of Loss
      Method of Analysis
             Security analysis methods may include charting, fundamental analysis, technical analysis, and
             cyclical analysis.

               The main sources of information include financial newspapers and magazines, company meetings,
               company conference calls and press releases, inspections of corporate activities, research materials
               prepared by others, corporate rating services, annual reports, prospectus and filings with the
               Securities and Exchange Commission. Other sources of information that COSTELLO ASSET
               MANAGEMENT INC. may use include Advyzon and Charles Schwab research services, and the
               World Wide Web.

                                  COSTELLO ASSET MANAGEMENT, INC.

Investment Strategies
    The primary investment strategy used on client accounts is asset allocation based on the risk tolerance
    of each client. This means that we may use more growth stocks in client accounts that seek higher
    returns and more dividend paying stock and shorter maturity bond investments for clients who are risk
    adverse. Portfolios are globally diversified through domestic and international sales of the individual
    stock investments. We may invest in companies based outside the United States but whose stock is
    traded on United States trading exchanges.

    The investment strategy for a managed account is based upon the objectives stated by the client during
    consultations. The client may change these objectives at any time. Each client signs an Investment
    Policy Questionnaire that documents their objectives and their desired investment strategy. All clients
    are required to contact COSTELLO ASSET MANAGEMENT, Inc. when their specific needs change.
    The Investment Policy Questionnaire is reviewed with the client at all meetings.

    Other investment strategies may include short and long-term purchases, trading, margin
    transactions, and option writing.

Covered Call Writing
   Covered call writing is the sale of in- or out-of-the-money call options against a long security position
   held in a client portfolio. This type of transaction is intended to generate income. It also serves to create
   partial downside protection in the event the security position declines in value. Income is received from
   the proceeds of the option sale. Such income may be reduced or lost to the extent it is determined to
   buy back the option position before its expiration. There can be no assurance that the security will not
   be called away by the option buyer, which will result in the client (option writer) to lose ownership in
   the security and incur potential unintended tax consequences. Covered call strategies are generally
   better suited for positions with lower price volatility.

Risk of Loss
    All investment programs have certain risks that are borne by the investor. Our investment approach
    constantly keeps the risk of loss in mind. Investors face the following investment risks:

           Interest-rate Risk: Fluctuation in interest rates may cause investment prices to fluctuate. For
               example, when interest rates rise, yields on existing bonds become less attractive, causing
               their market values to decline.
           Market Risk: The price of a security, bond, or mutual fund may drop in reaction to
               tangible and intangible events and conditions. This type of risk is caused by external
               factors independent of a security’s particular underlying circumstances. For example,
               political, economic and social conditions may trigger market events.
           Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a
               dollar next year, because purchasing power is eroding at the rate of inflation.
           Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar
               against the currency of the investment’s originating country. This is also referred to as
               exchange rate risk.
           Reinvestment Risk: This is the risk that future proceeds from investments may not have to be
               reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to
               fixed income securities.
           Business Risk: These risks are associated with a particular industry or a particular company
               within an industry. For example, oil-drilling companies depend on finding oil and refining
               it, a lengthy process, before they can generate profit. They carry a higher risk of
               profitability then an electric company, which generates its income from a steady stream of
               customers who buy electricity no matter what the economic environment is like.
           Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally,
               assets are more liquid if many traders are interested in a standardized product. For
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