Innis Investments LLC

Item 5 – Fees and Compensation

Our Basic Fee Schedule

We charge portfolio management fees start at 1% of the client’s total assets under
management, lowering to .4%, based on the amount of money under management with us.
Fees are payable in six-month increments, based upon the asset value as of the first day of
the current six-month billing period (or the initial value of the assets in the case of the
establishment of a new account). Because we issue our billing statements just after the
beginning of each billing period, the billing date is always somewhat less than a full six
months in advance, as permitted by applicable rules. If a client elects to close an account
prior to the end of a six-month billing period for which advance payment has been received,
any unearned fees, computed on a per diem, pro rata basis will be refunded. The billing
periods applicable to each client are based upon the month-end nearest to the original date
the client’s account was established. Fees are negotiable.

Fee Payment Options

Our clients may select from two options to pay for our services:

   •   Direct debiting (preferred). At the inception of the relationship and after the
       beginning of each billing period thereafter, we will notify your custodian of the
       amount of the fee due and payable to us through our fee schedule and contract.
       You and your custodian will see exactly how our requested fee is calculated and will
       be able to check the calculation. The custodian will deduct the fee from your
       account or, if you have more than one account, from the account you have
       designated to pay our advisory fees. Each month, you will receive a statement
       directly from your custodian showing all transactions, positions and credits/debits
       into or from your account, including in applicable months the advisory fees you have
       been charged.

   •   Pay-by-check. At the inception of an account and after the beginning of each billing
       period thereafter, we will send the client an invoice for our services. You will see
       exactly how our requested fee is calculated and you will be able to check the
       calculation. You may pay us by check or wire transfer.

Additional Fees and Expenses

Advisory fees payable to us do not include all the fees you will pay when we purchase or sell
securities for your account(s). The following list of fees or expenses are what you may pay

directly to third parties, whether a security is being purchased, sold or held in your
account(s) under our management. Fees charged are by the broker-dealer or custodian, not
Innis Investments, LLC. We do not receive, directly or indirectly, any of these fees charged
to you, except as noted above. They are paid to your broker, custodian or the mutual fund
or other investment you hold. Possible third-party fees include:

   •   Brokerage commissions
   •   Transaction fees
   •   Exchange fees
   •   SEC fees
   •   Mutual fund sales loads or 12b-1 fees
   •   Advisory fees and administrative fees charged by mutual funds and exchange traded
       funds
   •   Advisory fees charged by sub-advisers (if any are used for your account)
   •   Custodial fees
   •   Deferred sales charges (on mutual funds or annuities)
   •   Odd-lot differentials
   •   Deferred sales charges (charged by mutual funds)
   •   Transfer taxes
   •   Wire transfer and electronic fund processing fees
   •   Commissions or mark-ups / mark-downs on security transactions
   •   Insurance commissions and referral fees

Please see Item 12 of this brochure for further discussion of our brokerage practices.

Account Cancellation and Refunds

Client accounts may be cancelled at any time by either the client or Innis Investments, LLC
upon 30 days prior written notice.

Since our fees are payable slightly less than six months in advance, a refund will be due you
in the event your account is closed before the end of the six-month billing period for which
fees were paid, after the ten-day account closure notice period. Refunds are calculated by
dividing the number of days remaining in the billing period after the ten-day notice takes
effect by the total number of days in the billing period, times the total amount of fees that
were collected in advance for that particular billing period.

Item 7 – Types of Clients

We may provide our services to all types of clients, including among others the following:

   •   Individuals, including high net worth individuals

   •   Trusts, estates and charitable organizations

   •   Corporations or other business entities

   •   Endowments and foundations

   •   Not for profit entities

   •   IRAs and Roth IRAs

   •   401(k) plans (or individuals' accounts in such plans)

   •   403(b) plans (or individuals' accounts in such plans)

There is no minimum account size required to open an account or to maintain an account
once opened.