Girard Pension Services LLC

FEES AND COMPENSATION
Investment Advisory Fees:
Advisor charges a fee for providing investment management and consulting services to clients
that is based on a percentage of assets under management. The fee for Advisor’s services is as
follows:
Managed Investment Accounts           Annual Percentage
First $2 Million                      0.35%
Next $3 Million                       0.30%
Next $5 Million                       0.25%
Over $10 Million                      0.20%

Advisor’s fee can be negotiated and may differ from those stated because of the competitive bid
selection process administered by the various municipalities that make up the Municipal Pension
Plan System and includes factors such as size of the account, the services provided, changing
market conditions, other market-driven competitive factors, or other reasons.

Advisor’s fee is paid each quarter in advance and is based on the value of all assets (market value
or fair market value in the absence of market value, plus any credit balance or minus any debit
balance), being managed as of the end of the prior calendar quarter.

Advisor’s fee is deducted directly from client account assets held by the designated custodian
and requests for fee liquidations are processed through a third-party administrator, transfer agent,
or custodian of the plan assets. If insufficient cash is available to pay such fees, securities in an
amount equal to the balance of unpaid fees will be liquidated to pay for the unpaid balance.

In the event the advisory agreement is terminated, and the Advisor has received unearned fees,
the Advisor will prorate such fees as of the date of termination and promptly refund any

unearned portion to the client. In calculating a client’s reimbursement of fees, Advisor will pro
rate the reimbursement according to the number of days remaining in the billing period.

Other Fees and Expenses:
Internal Expenses: Exchange traded funds, mutual funds or sub-accounts of a variable annuity,
charge fees and expenses for their respective funds. These expenses are disclosed in the fund’s or
annuity’s prospectus and include some or all of the following: management fees, administration
fees, transaction charges, distribution fees and other fund or annuity expenses.

Custodian Fees: Custodians charge fees to client accounts maintained on their platform for the
custodial and trade execution services they provide. Custodian fees typically include ticket
charges, commissions, mark-ups and mark-downs, check, ACH and wire transfer fees, statement
and confirmation fees and retirement plan recordkeeping or custodial fees based on a percentage
of account assets. To the extent Advisor uses Charles Schwab & Co., Inc. as a custodian for
some of our client’s accounts, Schwab does not charge commissions and transaction fees for
U.S. listed equities and exchange traded funds.

Advisor does not share in any portion of the fees described in this section entitled “Other Fees
and Expenses.” Clients should review all fees charged by Advisor and others to fully understand
the total amount of fees they will pay. Please refer to the Brokerage Practices section below for
additional information.

Other Compensation:
Girard provides accounting, administrative, compliance and consulting services (“Pension
Services”) to municipal pension plans. Clients may elect to engage Girard to provide one or more
of these Pension Services. Compensation for Pension Services may be billed directly to a client
or received by Girard or an affiliated company in the following ways:

For clients utilizing the services of MG Trust Company and Matrix Settlement & Clearance
Services, LLC (collectively “Matrix”) for custodial and brokerage services, Matrix has entered
into sponsorship or revenue sharing arrangements with certain mutual fund companies that are
made available on their platform. Matrix retains a portion (10% ) of the revenue received from
these companies in which Girard client assets have been invested. Matrix then pays the
remainder of the revenue to Girard.

Clients utilizing a group annuity or variable annuity product on the Nationwide platform will
typically pay commissions and revenue sharing in the form of asset-based fees that are deducted
from the funding options available within the annuity product. Commissions and revenue sharing
are paid to affiliates of Girard by Nationwide.

Commissions and revenue sharing are received in lieu of Girard charging a plan separately for
Pension Services and may be more or less than what would be charged separately. Our clients
may enter into a separate direct billing arrangement with our firm or another vendor for Pension
Services at their discretion. The fees described present a conflict of interest as Girard or an
affiliated firm will benefit from receiving additional compensation and this will affect the
investment recommendations made by the advisor including foregoing the use of less expensive

mutual fund share classes or service providers. The compensation received by Girard and its
affiliates may exceed the compensation received by Girard for the services we provide to clients
if they are billed separately.

A client could invest in mutual funds or group annuity products without our services. In that
case, the client would not receive the services provided by our firm which are designed, among
other things, to assist the client in determining which investments are most appropriate to each
client’s financial condition and objectives. Clients also receive other services that are not paid for
or provided through the investment advisory agreement. Accordingly, the client should review
the fees charged by the funds, the fees incurred through the platform, and our investment
advisory fees to fully understand the total amount of fees to be paid by the client and to thereby
evaluate the services being provided.

PERFORMANCE BASED FEES AND SIDE BY SIDE MANAGEMENT
...

TYPES OF CLIENTS
Girard Pension Services, LLC provides investment management and pension administration
services to pension plans of municipal government entities.

METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK
OF LOSS
Advisor's investment philosophy is based on the principals of asset allocation and diversification.
The investment philosophy leads to diversification among different asset classes. Investments
may include ETF’s and mutual funds that are comprised of domestic and foreign equities,
(exchange listed or over the counter), real estate investment trusts and a variety of fixed income
securities including US Treasuries, agencies, mortgage-backed securities, corporate debt and
municipal debt. Client portfolios may also contain one or more of the following investments if
agreed upon between Advisor and client: individual stocks, exchange traded real estate
investment trusts, corporate bonds and government bonds.

Girard utilizes a proprietary research process to select investments to be utilized in client
portfolios. Girard also utilizes outside third party research to help with investment analysis. An
approved list of investments is maintained by the Investment Committee, which is charged with
the function of determining which investments are added and subtracted from the approved list.

Risks: There are a number of risks associated with the investment strategies offered by the
Advisor, including, but not limited to, the following:

Stock Risks: Portfolios managed by the Advisor are subject to stock market risk, which is the
chance that stock prices overall will decline. Stock markets tend to move in cycles, with periods
of rising prices and falling prices. Such risk will vary based on the percentage of stocks owned in
a given strategy and client portfolio.

Bond Risks: Bonds are subject to interest rate risk, which is the chance that bond prices overall
will decline because of rising interest rates. Interest rate risk will vary based on the percentage of
bonds owned in a given strategy. In addition, long-term bonds have a higher interest rate risk and
are much more sensitive to interest rate changes than are the prices of short-term bonds. Bonds
are also subject to credit risk, the chance that a bond issuer will fail to pay interest and principal
in a timely manner or, that negative perceptions of the issuer’s ability to make such payments
will cause the price of that bond to decline. Finally, some bonds may be subject to call risk. This
is the chance that in a declining interest rate environment the issuer of a bond will repay or call
securities with higher coupons before their maturity dates.

Asset Class Risks: Investments in specific asset classes entail different investment risks. For
example, small cap stocks (stocks with a market capitalization of 2 billion or less) tend to be
more volatile than large or mid-cap stocks. International and emerging market stocks include
risks due to currency fluctuations, foreign taxes, political instability, different financial
accounting standards and possibility of illiquid markets. Real estate investing includes risks such
as declines in the value of real estate, changing economic conditions, and changes in tax laws or
property taxes.

Risk of loss: Advisor utilizes a long-term approach to investing and typically will not attempt to
time the markets. Advisor will typically stay committed to its investment allocation and not seek
to liquidate a portfolio to avoid market losses. The strategic or tactical asset allocations
employed by the Advisor do not assure profit or protect against loss in declining markets. As
such, investing in securities involves risk and a client must be prepared to assume this risk.