Henry H Armstrong Associates Inc

ITEM 5: FEES AND COMPENSATION

The client can determine to engage Armstrong to provide discretionary and/or non-discretionary
investment advisory services on a fee basis.

       A. Fee Schedule Description

Armstrong offers continuous investment advisory services for a fee, calculated as a percentage of
assets under management. Our standard fee schedule is as follows:

1.00 percent on the First $5,000,000.00
0.90 percent on the Next $5,000,000.00
0.80 percent on the Next $5,000,000.00
0.70 percent over $15 Million
These rates are applied to the market value of all assets under management, including cash balances
that are available for investment, and are charged annually. Fees are in some cases negotiated with
a client as deemed appropriate by Armstrong. Fees are generally waived for employee and related
or family member accounts.
       B. Fee Billing

Armstrong calculates fees each quarter based upon our quarter-end market appraisal of the
portfolio, and the amount is billed in advance unless a client directs otherwise. Armstrong’s fee
can be deducted directly from the client’s assets held by the independent custodian or, if the client
prefers, they can pay the bill directly.

Two criteria must be met for the custodian to make payment of fees. They are as follows: (1) the
client must provide written authorization (either within the context of the brokerage account
application or a separate letter of authorization to the custodian) permitting the fees to be paid
directly from the client’s account held by the independent custodian; and (2) the custodian agrees

to send to the client a statement, at least quarterly, indicating all amounts disbursed from the
account including the amount of advisory fees paid directly to Armstrong.

Armstrong sends a copy of each client’s bill to the client. The bill shows the amount of the fee,
the value of the client’s assets on which the fee was based, and the method used to calculate the
fee. The account custodian does not verify the accuracy of Armstrong’s advisory fee calculation.

When calculating advisory fees, Armstrong will generally aggregate account values for each client
relationship, which will typically include accounts of both spouses and minor children and (at the
exclusive discretion of Armstrong) occasionally include adult children as well.

       C. Cash Balances

Armstrong considers cash to be an asset class. Cash held in the client’s investment account is
typically invested in a money market fund or swept into a money market bank account at the
client’s custodian. Armstrong generally includes cash and cash equivalents in the calculation of
assets under management and fees, with the exception of asset carve out arrangements which are
formalized based on the client's expressed need to set aside cash. During periods of exceedingly
low short-term interest rates, client fees paid on cash balances may exceed money market yields.
       D. Other Fees

Clients will incur brokerage commissions and other transaction costs for trades executed in their
account, to the extent applicable. For clients enrolled in Prime Brokerage a nominal fee also
applies. Clients who own mutual funds will be subject to the operating expense of the various
mutual funds in which they invest. Clients who own ETFs will be subject to the operating expenses
of the ETFs in which they invest. Armstrong does not accept or receive compensation for the sale
of securities or other investment products, including asset-based sales charges or service fees from
the sale, purchase, or redemption of mutual funds. (Please see Item 12 – Brokerage Practices for
more information about Armstrong’s brokerage practices.)
       E. Fee Refunds and Partial Fee Periods

If a client terminates their Management Agreement with us before the end of the billing period
they will receive a refund on a pro rata basis. If a client opens a new account in the middle of a
billing period, Armstrong will generally not charge the client for the first partial period in which
we manage the new account.

ITEM 7: TYPES OF CLIENTS
       A. Description

Armstrong provides investment advice to individuals, high net worth individuals, families, trusts,
estates, pension and profit-sharing plans, corporations, and charitable organizations.
       B. Account Opening and Account Minimums

Armstrong requires all clients to sign a Henry H. Armstrong Management Agreement. This
Agreement authorizes Armstrong to manage investments for a client’s account. It spells out the
terms of our engagement and does not commit the client to any fixed term of engagement. The
Management Agreement can be canceled at the client’s option at any time. Armstrong’s minimum
account size is $2 million, but Armstrong will accept accounts of lower value at its discretion.
Armstrong’s minimum fee per account is $20,000, which may be waived at its discretion.