Horter Investment Management LLC

Item 5   Fees and Compensation
  A.     Advisory Fees
         Our annual advisory fees for Investment Supervisory Services are assessed quarterly in
         arrears and are based upon a percentage of the average daily value of assets under
         management for the prior quarter.

         Fees and services may be negotiable based on a number of factors such as client type,
         asset class, pre-existing relationship, complexity and account size, anticipated future
         additional assets; related accounts; portfolio style, account composition, reports and other
         special circumstances or requirements. Some clients pay higher or lower fees than other
         clients.

         Discounts, not generally available to our advisory clients, may be offered to family members
         and friends of associated persons of our firm. Fees may only be increased by providing
         Client written notice thirty (30) days in advance.

         Advisory Fees in General
         Clients should note that similar advisory services may (or may not) be available from other
         registered (or unregistered) investment advisers for similar or lower fees.

         Annual Fee Schedule
         Advisory fees are generally determined based upon the following fee schedule below.
         However, as stated above, fees for certain strategies or accounts may fall outside of the
         stated ranges or are negotiated. The specific Annual Fee Schedule is identified in the
         Schedule of Services & Fees between Horter and each client.

           Portfolio Management Program                      Annual Fee Schedule
Third-Party Money Manager Program*                         1.99%

Tactical Institutional Mutual Funds*                       1.99%
Nationwide Advisory Solutions*                             1.99%
Retirement Plan Asset Management (Third-Party
                                                           1.99%
Money Managers) *
Retirement Plan Asset Management (Indexed Funds)           0.50%
Alternative Investments                                    1.25%
                                                           0.1% ($50 minimum
Non-Discretionary Accounts
                                                           quarterly)
Portfolio Management Program                               Annual Fee Schedule

*Description of Annual Fees
As the Fee Schedule above indicates, the maximum Annual Fee charged is 1.99%. Our
annual fee is comprised of an investment management fee, program administration fee, and
financial professional compensation. Descriptions of the fee compositions are provided
below. Fees are negotiable.

Investment Management
0.40% is paid to the Firm for providing the following services: Initial and ongoing manager /
fund due diligence, asset allocation, model design and research on new prospective
strategies, managers and funds. The portion of the clients advisory fee allocated to
investment management may be less than 0.40% in agreements that are entered into at a
negotiated rate.

In certain cases, a portion of this fee may be paid directly to Third-Party Money Managers.
When TFA funds are allocated to your Account, Horter has agreed to waive this portion of
the annual advisory fee proportional to the allocation of TFA in your account at the asset
level. When TFA is included in a multi-manager model, this portion of the fee will be charged
for all non-TFA assets in your account. As this fee is based on a maximum Annual Fee of
1.99%, the fee waiver for holding TFA Funds will be proportionately lower for clients with a
discounted client fee. Clients should be aware that certain conflicts of interest exist relating
to the use of TFA Funds.

Program Administration
0.35% on an annual basis and is paid to the Firm for providing the following services:
Technology, trading, account rebalancing, program compliance, reporting, account servicing,
billing, macro-economic research and general operations. This portion of the fee is
administrative in nature; is applicable to all accounts and is assessed regardless of the
assets held in the account.

     Financial Professional
     This portion of the Fee is paid to the Financial Professional(s) for providing investment
     advice (in the case of Horter advisors) or referring you to Horter (in the case of promoters or
     unaffiliated advisers), This portion of the fee will vary but typically ranges from 0.89% to
     1.24%.

B.   Payment of Fees
     Advisory fees are automatically debited from the client’s account in accordance with the
     terms set forth in the Client Agreement.

C.   Other Fees and Expenses
     In addition to the advisory fees described above, clients may be subject to other fees and
     expenses in connection with Horter’s advisory services.

     Custodian Expenses
     In addition to our advisory fees, clients are also responsible for the fees and expenses
     charged by custodians including, but not limited to, account maintenance fees and any
     trading fees or transaction charges that may be assessed for transactions in the client's
     account(s). Clients should refer to the custodian fee schedule provided at the account
     opening for a description of custodial fees that may apply to their account. Please refer to
     the "Brokerage Practices" section (Item 12) of this Form ADV for additional information.

     Nationwide Fees
     Investment advisory clients who invest in a variable annuity with Nationwide Advisory
     Solutions are charged a monthly fee of $20 per month, per contract, paid directly to
     Nationwide Advisory Solutions.

     Mutual Fund & ETF Fees
     These fees and expenses are described in each fund's prospectus and typically include
     annual ongoing expenses and transaction fees paid when you buy or sell shares in a fund.
     These fees are separated and are in addition to the fees charged by Horter for its investment
...

Item 7   Types of Clients
         Horter provides advisory services to the following types of clients:

                •   Individuals (other than high net worth individuals), primarily aged 50 and over.
                •   High net worth individuals
                •   Trusts, estates
                •   Corporations or Other Businesses
                •   Pension and profit-sharing plans (other than plan participants)
                •   Insurance Companies