CWA Naples LLC

Item 5: Fees and Compensation

 A. Fee Schedule

 Investment Advisory Fees

The following table summarizes CWA Naples’s current fee structure for investment
advisory services.

          Total Assets Under Management                     Annual Fee
         Up to $2,500,000                                       1.15%
         Next $2,500,000 ($2.5MM to $5MM)                       1.00%
         Next $10,000,000 ($5MM to $15MM)                       0.85%
         Next $10,000,000 ($15MM to $25MM)                      0.75%
         Next $10,000,000 ($25MM to $35MM)                      0.65%
         Next $10,000,000 ($35MM to $45MM)                      0.55%
         Any assets over $45,000,000                            0.50%

Investment advisory fees are negotiable depending upon the needs of the client and
complexity of the situation, and the final fee schedule is attached to each client’s IMA.
CWA Naples and CWA maintain a fee-sharing arrangement. Clients do not pay more
for investment advisory services than what is disclosed in their IMA.

Fees are calculated on the net asset value as of the end of the prior quarter of each
client’s account and paid quarterly in advance, and clients may terminate their
contracts with thirty days’ prior written notice. Refunds are given on a prorated basis,
based on the number of days remaining in a quarter at the point of termination. The
point of termination is the shorter of thirty-days of receiving notification or the end
of the quarter. The fee refunded will be the balance of the fees collected in advance
minus the daily rate* times the number of days in the quarter up to and including the
day of termination. (*The daily rate is calculated by dividing the quarterly AUM fee
by the number of days in the termination quarter). Clients may terminate their
contracts without penalty, within 5 business days of signing the advisory contract.
Investment advisory fees are withdrawn directly from the client’s account(s) with
client written authorization.

Depending on each client’s unique circumstances and arrangements, CWA Naples
management fees are exclusive of any fees and/or expenses charged by third parties.
Such third-party expenses include custodial fees, brokerage commissions (see Item

Item 7: Types of Clients

CWA Naples generally provides advisory services to the following types of clients:

          ❖ Individuals
          ❖ High-Net-Worth Individuals
          ❖ Corporations and Other Business Entities

Minimum Account Size

CWA Naples does not have a minimum account size for client accounts.