Grant Koehler & Levin Ltd

Fees and Compensation
Description
          GRANT, KOEHLER & LEVIN LTD. bases its fees on a percentage of assets under
          management, hourly charges and fixed fees (not including subscription fees).
          Please see the Types of Agreements section above for additional information
          regarding our services, fees and agreement terms.
           Some Retainer Agreements may be priced based on the complexity of work,
           especially when asset management is not the most significant part of the
           relationship.
           Financial plans are priced according to the degree of complexity associated with the
           client’s situation.
           Fees are negotiable based on account size or other considerations.
Fee Billing
           Generally, investment management fees are billed quarterly, in ADVANCE, meaning
           that we invoice you BEFORE the three-month billing period has ENDED. However,
           certain client accounts are billed in arrears. Whether billed in advance or in arrears,
           fees are usually deducted from a designated client custodian account to facilitate
           billing. The clients must consent in advance to direct debiting of their investment
           accounts. If a client prefers, GRANT, KOEHLER & LEVIN LTD. will send an invoice
           and the client may pay by check.
           Fees for financial plans are billed 0% in advance, with the balance due upon delivery
           of the financial plan.

                                 GRANT, KOEHLER & LEVIN LTD.

Other Fees
         Custodians may charge transaction fees on purchases or sales of securities, mutual
         funds and exchange-traded funds. Custodians may also charge annual fees for IRA
         accounts and account inactivity fees.
Expense Ratios
         Mutual funds and Exchange-Traded Funds (ETFs) charge fees and expenses
         applicable to all shareholders in the mutual fund or ETF. These fees are called an
         expense ratio. For example, an expense ratio of 0.50 means that the fund charges
         0.5% annually. These fees are in addition to the fees paid by you to GRANT,
         KOEHLER & LEVIN LTD.
           Performance figures quoted by funds in various publications are after their fees have
           been deducted, but before GRANT, KOEHLER & LEVIN LTD.’s fees.
Past Due Accounts and Termination of Agreement
         GRANT, KOEHLER & LEVIN LTD. reserves the right to stop work on any account
         that is more than 90 days overdue. In addition, GRANT, KOEHLER & LEVIN LTD.
         reserves the right to terminate any financial planning engagement where a client has
         willfully concealed or has refused to provide pertinent information about financial
         situations when necessary and appropriate, in GRANT, KOEHLER & LEVIN LTD.’s
         judgment, to providing proper financial advice. Any unused portion of fees collected
         in advance will be refunded within 30 days. Fees are refunded on a pro rata basis
         for the portion of the quarter not completed.
Account Valuation Practices
         GRANT, KOEHLER & LEVIN LTD. uses market values as provided by our clients’
         custodians, to calculate investment performance and client fees. While this scenario
         rarely occurs, if the custodian does not supply a price or we believe a price supplied
         is not indicative of an accurate market value we will ask the custodian to update their
         pricing on that particular security. While as a matter of practice we strive to not value
         client securities, we do maintain processes to establish a fair value for a security in
         the event the custodian is unable to provide a price we feel is indicative of an
         accurate market value.

Types of Clients
Description
          GRANT, KOEHLER & LEVIN LTD. generally provides investment advice to
          individuals, pension and profit sharing plans, trusts, estates, charitable organizations,
          corporations and business entities.
           Client relationships vary in scope and length of service.
Account Minimums
         Accounts shall have $250,000 as the minimum. Further funding expectations or
         other special considerations may permit an exception to this rule.
Methods of Analysis, Investment Strategies and Risk of Loss