D'Arcy Capital Management LLC

Item 5 – Fees and Compensation

In addition to the information provided in Item 4, Advisory Business, this section provides details
regarding Advisor’s services along with descriptions of each service’s fees and compensation
arrangements.

Asset Management and Financial Planning Services

We offer asset management services that include giving continuous investment advice and/or making
investments for you based on your individual needs, goals and objectives. We offer a customized and
individualized investment program providing you with advice regarding various asset classes, ongoing
assistance with evaluating and selecting investments, adjusting and rebalancing portfolios.

We have two management programs. The first is an asset allocation program created specific to your
objectives. The securities used in these allocations may include mutual funds, exchange traded funds,
separate account managers, individual bonds, individual stocks, certificates of deposit and municipal
bonds. Depending upon your individual needs, portfolios can range from 100% fixed income investments
to 100% equity investments.

The second program uses a non-diversified approach utilizing individual stocks and/or bonds aimed at
achieving your specific goal. Strategies include large or small cap value stocks, individual bonds and a
balanced strategy that includes both large or small cap value stocks and bonds. Bonds can be both
taxable and non-taxable (municipal bonds). Strategies can also use exchange traded funds and mutual
funds.

We recommend that your assets be maintained in a brokerage account with Fidelity Brokerage Services
LLC (Fidelity), an SEC registered broker/dealer and member NYSE/SIPC. See Item 12, Brokerage
Practices, for additional discussion on our recommendation and use of Fidelity. However, you are free to
select any account custodian you wish. We assist you in establishing a managed account with Fidelity or
another qualified custodian that you select. The qualified account custodian maintains custody of your
funds and securities. We do not act as custodian and so do not have direct access to your funds and
securities except to have advisory fees deducted from your account with your prior written authorization.

You authorize us to have trading authorization on your accounts and we provide management services
on a discretionary basis only. On a discretionary basis, we make all decisions to buy, sell or hold
securities, cash or other investments in your managed account in our sole discretion without consulting
with you before making any transactions. You must provide us with written authorization to exercise this
discretionary authority, and you can place reasonable restrictions and limitations on the discretionary
authority. See Item 16, Investment Discretion, for additional discussion on discretionary authority.

We charge for asset management services based on a percentage of assets under management. Fees
are billed quarterly in advance and calculated based on the fair market value of the account as of the end
of the previous quarter as follows:

                 Account Value                   Maximum Annual Fee

                 Up to $1,000,000                 1.75%
                 $1,000,001 to $10,000,000        1.00%
                 $10,000,001 to $25,000,000       0.80%

D’Arcy Capital Management LLC                                                             Disclosure Brochure

                 Over $25,000,001                  Negotiable

Fees are negotiable based on the complexity of your situation, the composition of your account and the
potential for additional account deposits. We always disclose the fee to you before we provide any
services. For assets managed in the individual stock programs (either Large Cap Value or Small Cap
Value) we charge an additional 0.50% annually; however, our total fee will not exceed 1.75% annually.
For assets managed in the cash management program, the fee is 0.25% annually. Separate account
managers have their own fees which are separate and in addition to our management fee; the
combination of our fee, the separate account manager fee, and custodian fee may exceed 1.75%
annually. If an agreement for services is executed mid-period, the initial fee is prorated based on the
number of days services were provided during the first billing period.

At your option, fees can either be billed directly to you or automatically deducted from an account
designated by you and paid directly to us by the account custodian. If fees are billed directly, they are
due immediately upon receipt of our billing statement. If fees are deducted from an account, you must
provide the account custodian with written authorization to have the fees deducted from the account and
paid directly to us. At least quarterly, you receive an account statement from your account custodian
detailing transactions in your account, including advisory fees charged. You should review the account
statements received from the account custodian and verify that appropriate advisory fees are being
deducted. The custodian will not verify the accuracy of the advisory fees deducted.

Fidelity generally does not charge separately for maintaining custody of your accounts but other qualified
custodians selected by you may charge a separate custody fee. However, account custodians may
charge brokerage commissions and/or transaction fees directly to you. We do not receive any portion of
the commission or fees from either the custodian or from you. In addition, you will incur certain charges
imposed by third parties other than us in connection with investments made through your account,
including, but not limited to, mutual fund sales loads, 12(b)-1 fees and surrender charges, variable annuity
fees and surrender charges and IRA and qualified retirement plan fees. Our management fees are
separate and distinct from the fees and expenses charged by investment company securities that may be
...

Item 7 – Types of Clients

We generally provide investment advice to the following types of clients.

    •   Individuals (including high net worth individuals)
    •   Trusts, estates, or charitable organizations
    •   Institutions, profit sharing plans, and qualified retirement plans
    •   Corporations or business entities other than those listed above

Minimum Investment Amounts Required

We generally require clients to maintain a minimum account size of $500,000.
The minimum investment for the Global Large Cap Value portfolios is $250,000.
The minimum investment for the Small Cap Value portfolios is $250,000.
The minimum investment for our bond management portfolios is $1,000,000.
We may waive or reduce these minimums at our discretion.

D’Arcy Capital Management LLC                                                           Disclosure Brochure