First Endowment Development Corp

ITEM 5: FEES AND COMPENSATION

   INVESTMENT ADVISORY SERVICES
   Fees charged for ongoing investment advisory services vary from client to client and are
   agreed upon prior to engagement. Some investment advisory client fees are charged an
   annual flat fee when combined with additional planning services. Flat fees vary based
   upon the scope of the engagement. Other clients are charged a fee as a percentage of
   assets. Annual fees range from 0.20% to 0.70% per year based on the value of the
   managed portfolio and scope of services Comstock provides. For new clients, Comstock
   generally requires a minimum of $10,000,000 in assets under management. Exceptions
   to the minimum are made at the sole discretion of Comstock. Fees applying to new clients
   could be greater than to existing clients having the same portfolio complexity and value.

   The fixed annual flat fee is typically greater on a percentage of assets basis than its
   standard portfolio management fee rate, due to the additional services provided. Flat fees
   will increase by 3% annually to account for inflation. The increased fee is made effective
   with the Q1 billing and applies through the Q4 billing of that year. Fees are billed quarterly
   in advance. Comstock will provide written notice in advance of the annual fee increase.

   Typically, Comstock charges a fee for the initial review of portfolio allocation, financial and
   estate planning, succession issues and other factors that often impact a client’s financial
   goals. This review is called a Present Position Analysis (PPA) and fees will typically range
   between $25,000 and $150,000 and will be agreed upon prior to engagement. This
   analysis is available either as a standalone engagement or as part of an ongoing
   engagement.

   Comstock also advises individual donors of public nonprofit organizations on specific gift
   recommendations and provides assistance to the donor's advisors. Such services are
   provided on a pre-agreed upon fee prior to services being rendered. When appropriate,
   fees are charged based on a project fee or monthly retainer and are determined based on
   the specific needs of the client.

   GENERAL PROVISIONS
   The fee quoted under any of the above advisory services is based on the complexity of
   the circumstances presented by the client. All fees are agreed to in advance and are only
   subject to change if agreed upon by the client in writing.

   Comstock does not price any securities and relies instead on recognized and independent
   pricing services and/or qualified custodians for timely valuation information for advisory
   client securities and portfolios. For securities in which valuation information is not readily
   available from independent sources, e.g., hedge funds, private placements, illiquid
   securities, etc., Comstock relies on the issuer to provide valuation information to both the
   clients and the custodians that hold such securities.

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   Comstock’s fees and the method of payment of the fees are clearly described in each
   client’s investment consulting agreement.

   Ongoing client fees are invoiced on a monthly or quarterly basis according to the client’s
   preference. Fees are billed in advance, and when charged on a percent of assets under
   management, Comstock uses the valuation provided by each account’s custodian. All
   invoices are due and payable within 30 days of receipt. In some cases, Comstock may
   allow fee arrangements in which fees are paid in arrears. The specific terms of all fee
   arrangements will be dictated by the terms outlined in the client’s investment consulting
   agreement.

   If fees are to be deducted from a client’s custodial account, the client must give permission
   in writing before a deduction occurs. Ordinarily the client grants this authority in the
   custody agreement and application provided by the delegated custodian. When such is
   the case, Comstock sends an invoice to the client, detailing the value of the account at
   the time the fee calculation was made, the exact basis on which the fees were calculated
   (i.e., the percentage applied to the assets under advisement), and the dollar amount of
   fees to be deducted. Otherwise, clients pay by check or wire.

   Fees under any of the advisory engagements may be canceled within the first 5 business
   days after the initial engagement without penalty. If a client terminates the engagement
   after 5 business days, but within 30 days, and prior to the work being completed, a 50%
   refund of the initial fee paid will be made. If work has been in progress for more than 30
   days but less than a year, a refund of 25% of the prepaid fee will be made. Notice of
   termination must be in writing and will be effective upon receipt by Comstock.

   Fees charged by funds, custodians, banks and or managers are in addition to any fees
   paid to Comstock.

   Fees for all advisory services are likely to vary from client to client with similar sized
   portfolios and are determined upon the specific circumstances of each engagement.
   Therefore, some clients will be paying more than others.

   FEES FOR STAND ALONE PROJECTS
   Many of Comstock’s engagements are project specific, including the Present Position
   Analysis, and are charged on a one-time basis. When such is the case, ½ of the agreed
   upon fee is due upon engagement. The balance is due upon the client’s agreement that
   the work has been completed, which is usually within 6 months.

   Comstock serves as an expert witness in investment dispute circumstances under a pre-
   agreed upon project fee.

   Comstock also provides additional planning services on a stand-alone project basis, as
   needed. Fees for such services are mutually agreed upon prior to engagement. In some
...

ITEM 7:      TYPES OF CLIENTS

   For new clients, Comstock generally requires a minimum of $10,000,000 in assets under
   management. Exceptions to the minimum are made at the sole discretion of Comstock.

   Individuals & Foundations with investment assets of $10 million or greater, desiring
   investment advisory service.

   Ultra-High Net Worth Families with investment assets of $20 million or greater faced
   with complex wealth management, transfer and administrative issues including
   multifaceted organizations, partnerships, and private companies involving family and
   internal professional staff.

   Public or Private Tax-Exempt Organizations with investment assets of $20 million or
   greater.