Embarcadero Financial Investment Advisory LLC

Item 5 - FEES AND COMPENSATION

ADVISORY FEES
EFIA assesses an annual management fee which is prorated and assessed quarterly in arrears,
based on the daily average market value of each of the client’s account(s) during the
preceding quarter for which security quotes are available. Market value includes all cash,
money market balances and the value of all assets held in the account and supervised by
EFIA as shown on the client reports provided by EFIA. EFIA’s asset under management fee
schedule is as follows:

                           Value of Assets Under
  Breakpoints                                                     Annual Fee as % of Assets
                           Management
  On the first             $1,000,000 or less                                1.20%

  On amount between        $1,000,001 to $2,000,000                          1.00%

  On amount between        $2,000,001 to $3,000,000                           0.9%

  On amount between        $3,000,001 to $5,000,000                           0.8%
  On the amount over       $5,000,001                                        0.70%
  Minimum Annual Investment Management Fee*                                  $3,000

*Under certain circumstances, based upon the nature of the Account and the services
requested, EFIA in its sole discretion may modify or waive the minimum annual fee.

FINANCIAL PLANNING AND CONSULTATION FEES
For its financial planning services, EFIA may charge an hourly fee of $450 or provide services
on the basis of project or fixed fee ranging from $1,500 to $50,000, depending upon the
complexity of a Client’s requirements or objectives. Project and general financial planning
fees are paid in no less than two parts, with the first portion a deposit equal to no less than
20% of the assumed work. If after 30 days from the signed agreement, the client wishes to
terminate the agreement the deposit on the project or fixed fee may be returned in full. The
client’s refund request must be made in writing and delivered to the EFIA offices. EFIA is not
obligated to provide any already completed agreed upon work if the full refund option is
exercised. Any refund of fees beyond the 30-day window is provided at the discretion of EFIA
on a pro rata basis, if at all.

Under certain circumstances, EFIA also accepts sales fees or commissions from the issuers of
specified securities and insurance products when EFIA clients purchase those products.
(Please see additional disclosures under General Fee Disclosures and Fund Disclosures
below). All fees are negotiable and subject to the particular circumstances of the client.

The client’s investment management fee to Advisor is determined in accordance with the
above standard fee structure, with exceptions negotiated on a case-by-case basis at
Advisor’s discretion. Any deviations from the standard fee structure are based upon a
number of factors including the amount of work involved, the amount of assets placed under
management and the attention needed to manage the account.

Clients customarily authorize EFIA to deduct its quarterly investment advisory fee directly from
their custodial account. This authorization is granted under the terms of the client’s signed
investment management agreement and the client’s instructions to the custodian. EFIA
sends the client a copy of the investment advisory fee invoice at the same time it requests
payment from the client’s custodian. It is the client’s responsibility to verify the accuracy of
the fee calculation, as the custodian will not determine whether the fee is properly
calculated.

To the extent that a client authorizes the use of margin, and margin is thereafter employed
by our portfolio managers in the management of the client’s portfolio, the market value of
the client’s account and corresponding fee payable by the client to EFIA may be increased.
As a result, in addition to understanding and assuming the additional principal risks
associated with the use of margin, clients authorizing margin are advised of the potential
conflict of interest whereby the client’s decision to employ margin may correspondingly
increase the management fee payable to the Firm. Accordingly, the decision as to whether
to employ margin is left to the sole discretion of client.

GENERAL FEE DISCLOSURE

EFIA believes its fees are competitive with those fees charged by other investment advisors
for comparable services. However, comparable services may be available from other
sources for lower fees than those charged by EFIA.

CUSTODIAN AND BROKERAGE FEES
Clients incur certain charges imposed by their custodians and other third parties such as
custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions. Additionally, clients will incur charges by the executing broker-dealer in the
form of brokerage charges and transaction fees on the investment transactions entered into
for their account(s). All of these charges, fees and charges are in addition to Advisor’s
investment management fee.

COMMISSION AND SALES FEE DISCLOSURES
Sales Commission or Fee Payment Credits for Clients That Place Assets Under Management
With EFIA. Some investment products (certain third-party management programs identified
below, mutual funds, insurance and annuities) are available only on a commission or other
fee basis. In order to allow EFIA the widest possible selection of appropriate investment
products for its clients’ investment accounts, and in order to minimize any potential conflict
of interest resulting from the payment to EFIA or its personnel of a sales commission or fee by
the issuers of such investment or insurance/annuity products, EFIA may either credit against
management fees or exclude the assets from portfolio valuation altogether the amounts
charged its clients attributable to any sales "load", commission or fee paid by the issuer to
...

Item 7 - TYPES OF CLIENTS

EFIA provides investment advice, financial planning and advice unrelated to securities to
individuals, pension and profit-sharing plans, trusts, estates and charitable organizations and
corporations or other business entity types.

EFIA requires a minimum account size of $100,000, although in certain circumstances,
separate client accounts may be aggregated to meet this minimum. Based upon the nature
of the Account and the services requested, EFIA, in its sole discretion may waive the minimum
account size.