ITS Asset Management LP

ITEM 5 - FEES AND COMPENSATION

ITS ASSET MANAGEMENT

ADVISORY FEES

ITS is compensated for the investment advisory (i.e. portfolio management) services it provides to its
clients through an advisory fee charged to the clients. The fee is calculated as a percentage of the total
asset value of the client’s ITS-managed account. At the present time, the annual advisory fee rate can
vary among ITS’s current clients using the same ITS program. One thing has remained unchanged over
the years—our maximum annual advisory fee to our clients has never exceeded 2.00%.

CURRENT FEE SCHEDULE

The fee shown below is the maximum ITS annual advisory fee, regardless of account size, at all
investment platforms where the indicated management program is available.

                             Dynamic, Global              IP
                             Premier
 All types of individual,    2.00%                        1.00%
 business, self-directed
 (401k, 403b, etc.) and
 sponsor-directed (401k,
 PSP, DBP, etc.)
 retirement accounts

*Fee shown is total ITS fee to client. There is no additional charge from ITS for solicitor fee payment to
the client’s financial professional.

Variation in the fee rate among clients could result from factors such as the account’s inception date at
ITS, account or household asset size, whether the account is an ITS employee or solicitor account eligible
for a reduced rate, or if it participates in an employer-sponsored retirement plan (where advisory and
other fees can vary from plan to plan). There are also other factors that could impact the advisory fee
rate such as special arrangements negotiated between ITS and outside strategic partner firms that refer
clients to ITS. Clients can refer to their copy of the ITS disclosure materials or ITS New Account
Application that was provided for their records if they are unsure of the annual advisory fee rate being
assessed on their managed account. Clients can also review their account statement provided directly by
the custodian (i.e. Fidelity, Constellation, etc.) which will include an entry for each advisory fee paid on a
quarterly basis. Clients can also contact their financial professional or ITS directly for this information.

                             565 Washington Ave, Suite 7, North Haven, CT 06473
                                          Phone: (203) 234-9499

While ITS’s advisory fee is generally not negotiable, consideration could be given in select circumstances
based on account size or other factors at the discretion of ITS. Additionally, some flexibility (limited to
specific platforms) is built into the current fee schedule for Dynamic and Global Premier accounts valued
at $100,000 and above. On these accounts, the client’s financial professional can, at his/her discretion,
elect to reduce the solicitor fee reallowance he/ she receives from ITS in accordance with fee
reallowance guidelines established by ITS. The fee reduction is passed on directly to the client,
effectively reducing the annual advisory fee rate. More information about the relationship between ITS
and solicitors (i.e. financial professionals who refer their clients to ITS) is provided to the client in the
Solicitor’s Separate Disclosure Statement. This document is included as an integral part of the ITS New
Account Application and requires acknowledgment and signature of the client.

PAYMENT OF ADVISORY FEE

ITS’s advisory fee is paid through automatic liquidation (redemption of shares) from the client’s account.
The fee is assessed on a calendar quarterly basis and prepaid for each quarter in advance. Therefore, the
advisory fee amount liquidated each quarter, and appearing on the client’s custodial account statement,
is calculated at a rate of one-quarter of the annual rate indicated on the client’s ITS New Account
Application (or in accordance with the schedule of fees agreed upon for the retirement plan). Through
the automatic fee liquidation process, the custodian of the client’s account collects and distributes the
advisory fees to ITS. To maintain sufficient liquidity for the advisory fee deduction, an approximate 1%
money market allocation can be maintained in the client’s managed account, where applicable.

The following table shows the procedure (depending on the billing procedure of the custodial platform
the client utilizes) followed in the deduction of the ITS advisory fee from the client’s account once the
client’s assets to be managed are received (either by transfer to or new investment) at the custodial
investment platform selected by the client:

                                              Fees Assessed in Advance (Fidelity; CTC;
                                              Axos)
                   New Account—               Fee prorated to end of calendar quarter
                   Received Intra-Quarter:    is deducted immediately based on value
                                              of asset transfer to or new investment
                                              at custodial platform

                   Established Account—       Full quarterly fee is deducted within the
                   Full Quarter:              first few weeks of the current calendar
                                              quarter and is based on account’s value
                                              on last business day of preceding
                                              quarter
                   Addition/Deposit to        Fee prorated to end of calendar quarter
                   Account                    is deducted immediately based on value
                                              of addition/deposit

                             565 Washington Ave, Suite 7, North Haven, CT 06473
                                          Phone: (203) 234-9499

REFUND OF ADVISORY FEE

A client of ITS can cancel the advisory services of ITS at anytime so desired. Otherwise, the ITS Client
...

ITEM 7 - TYPES OF CLIENTS
ITS ASSET MANAGEMENT

ITS provides its advisory services to various types of clients including individuals, corporations, pension
and profit-sharing plans, charitable organizations, and other investment advisors. The vast majority of
ITS-managed accounts are those of individuals. These include various types of accounts such as IRA’s,
SEP’s, 403(b)’s, 401(k)’s, estates, and trusts.

SERVICES PROVIDED TO ERISA RETIREMENT ACCOUNTS

Advisor provides its advisory services to client accounts regulated under ERISA (Employee Retirement
Income Security Act). These accounts are typically qualified retirement plans established and maintained
by a sponsor employing firm and include accounts such as 401(k) plans, pension plans, profit-sharing
plans, 403(b) plans, among others. When Advisor provides investment advice to you regarding your
retirement plan account Advisor is a fiduciary within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts. The way Advisor makes money can create some conflicts with your interests, so
Advisor operates as a fiduciary which requires Advisor to act in your best interest and not put our
interest ahead of yours.

Essentially, the advisory services provided to ERISA accounts are the same services as provided to non-
ERISA accounts—providing a selection of investment strategies utilizing model portfolios designed and
managed in keeping with our DAPM formula rather than on a client-customized basis. Otherwise,
Advisor provides no other services to retirement plans or sponsors in relation to 1) legal or
administrative structuring or setup of the plan, 2) consultations, selection, or monitoring with respect to
other service providers, managers, etc., to the plan, or 3) accounting, recordkeeping, or tax-related
computations or reporting.

Advisor does not market its advisory services directly to the retirement plan marketplace but, as with
non-ERISA accounts, obtains ERISA accounts through the presentation of Advisor’s services by
independent financial professionals. Upon request, Advisor occasionally participates in participant
enrollment meetings to assist the financial professional in the presentation of Advisor’s services;
however, it is the employing firm or plan sponsor that is obligated to organize and coordinate such
meetings for plan participants.

Advisor currently provides its services to retirement plans where, depending on the structure of the
individual plan, the services were elected by 1) the plan sponsor for the total plan assets, or 2) the plan
sponsor as a managed services option for participants to elect individually, or 3) the individual
participant where the sponsor assumes no involvement in the selection of investment options for plan
participants. Also dependent on the plan, either the financial professional or an independent plan
consultant engaged by the plan sponsor assumes the responsibility to evaluate the financial needs of the

                             565 Washington Ave, Suite 7, North Haven, CT 06473
                                          Phone: (203) 234-9499

plan and/or participant and determine whether Advisor’s strategies are (and remain on an ongoing
basis) an appropriate and suitable option. A plan sponsor that is involved in the selection of Advisor in
an asset management capacity for the plan retains the fiduciary responsibility for the ongoing
monitoring of Advisor’s performance, and reserves the authority to terminate the services of Advisor for
the plan and its participants.

Certain plans contain “automatic enrollment” and “opt out” provisions in relation to managed services
options such as Advisor. This means that, if the plan sponsor selected Advisor as an approved managed
services option to the plan, participants are automatically enrolled into a designated Advisor program
based on their age. The participant then has the ability to change the assigned program or opt out of
Advisor’s managed services altogether. By opting out of managed services, the participant can “self
direct” or individually make his/her own investment choices in accordance with alternative investment
options offered under the plan. Where a participant does not opt out of Advisor’s services, it remains
the responsibility of the financial professional and/or independent consultant to evaluate if and when a
change to the assigned, age-based strategy is warranted for the individual participant.

Advisor receives direct compensation only from ERISA accounts. This means that Advisor is
compensated for the advisory services it provides solely through the payment of its advisory fee. Advisor
receives no indirect or other compensation of any kind in relation to the retirement plan account, such
as receipt of 12b-1 fees, soft dollar benefits, or any other type of brokerage, consulting, or service fees.

Advisor compensates the introducing financial professional through payment of a solicitor’s fee. Both
the Advisor’s advisory fee rate and the compensation arrangement with the solicitor are disclosed in
Advisor’s account paperwork for completion by the plan sponsor/participant.

PTS ASSET MANAGEMENT

Our account size minimum is negotiable, but we encourage accounts of $50,000 or more. We manage
for just about all types of Investors including corporations, non-profits, families, retirement account
trustees, etc. We state in our literature, “We strongly suggest you do not use this service if you have a
short-term time horizon.” Hence, the one type of investor we discourage from using our services are
speculative investors seeking to make a lot of money over a short period of time.