Gilder Gagnon Howe & Co LLC

ITEM 5 - FEES AND COMPENSATION
clients must establish a Prime Broker Account at NFS.
There is a minimum equity requirement of $105,000.00
                                                                 Description
for the establishment of a Prime Broker account. Prime
                                                                 GGHC receives compensation for its investment advisory
Broker paperwork is included in the new account
                                                                 services, which is specified in the client’s investment
documentation sent to all new clients. Account equities
                                                                 advisory agreement with GGHC. The compensation
are reviewed daily for Prime Broker qualification. If a
                                                                 structure will vary depending on the type of account and
client has more than one account at GGHC with the same
                                                                 is not subject to negotiation. Non-retirement accounts
ownership title, the equity values are combined to meet
                                                                 are charged a transaction based fee (also known as a
the minimum requirement.
                                                                 commission) on each trade and will vary depending on
Clients who have a non-retirement margin account must            the type of security (please see Commission Schedule -
sign a margin agreement with NFS to be able to trade on          Non-Retirement Accounts for details on the commission
margin. This agreement discusses the risks associated            schedule). Each commission payment will adversely affect
with trading on margin, including borrowing money to             the performance of the account. Certain types of trades
use securities as collateral to purchase additional              or accounts qualify for standard discounts, which are
securities and sell securities short. Please see “Other          described below following the commission schedule.
Expenses” for other expenses associated with margin
                                                                 GGHC bears the cost of trade execution for domestic
accounts and “Other Compensation- Payments and
                                                                 securities, which is less than the amount of commissions
Credits from NFS to GGHC” with regards to NFS sharing
                                                                 GGHC charges its clients, and means that GGHC earns a
revenue with NFS.
                                                                 profit on each trade. For foreign securities, the cost of
In addition, clients who have a non-retirement cash              trade execution is embedded in the price of the stock.
account or retirement account that want to participate in        Note regardless of trade execution costs, clients pay
an optional fully paid lending program with NFS, must            GGHC a commission on each trade. Commissions paid by
sign a separate agreement and other ancillary                    clients include the cost of investment advisory services,
documents. This program offers clients the potential to          custody and brokerage services (Please see Other
receive additional incremental income by loaning out the         Expenses for trades executed in foreign markets and
fully paid shares and receiving interest payment. Please         Commission Schedule - Non-Retirement Accounts).
see “Other Compensation – Payments and Credits from
                                                                 Retirement accounts are charged an annualized bundled
NFS to GGHC” for information regarding NFS sharing
                                                                 or “wrap” fee based on the account’s assets under
revenue with GGHC.
                                                                 management, valued on a month-end basis and paid
At any time, a client may terminate GGHC’s Investment            monthly in arrears. The wrap fee covers investment
Advisory Agreement by providing GGHC with written                advisory services, most execution costs (see “Other
notice. GGHC may terminate the Investment Advisory               Expenses”), and other services, such as custody,
Agreement upon delivery of 30 days’ written notice to            recordkeeping and reporting (no additional GGHC
the client. Unless otherwise mutually agreed to by GGHC          commissions are paid by retirement accounts for trades
and the client, upon termination, GGHC will commence             executed in these accounts).
an orderly liquidation of the securities and any other
                                                                 GGHC’s standard commission and wrap fee rate is not
non-cash assets in the account in the normal course of
                                                                 negotiable.
business. The risks associated with such liquidation will
be borne exclusively by the client, as will any
commissions resulting from the liquidation for
non-retirement accounts. Retirement accounts pay an

Commission Schedule -                                              OTHER COMMISSIONS (2% LIMIT)
Non-Retirement Accounts                                            While GGHC primarily purchases equities for client
                                                                   accounts, we may occasionally purchase options, debt
COMMISSIONS ON EQUITY TRADES                                       securities/bonds, and ETFs.

For non-retirement accounts, commissions on equity                 Options—GGHC’s standard commissions on option
trades, including ETFs, rights or warrants are charged at a        trades are based on the premium price (the price paid to
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