Keen Capital LLC

Item 5: Fees and Compensation

    Keen Capital’s fees for Investment Management are based on an annual percentage of assets
    under management or an annual fixed dollar fee. The maximum annual advisory fee for accounts
    paying a percentage of assets under management is 1.25%. The specific advisory fees are set forth
    in each client’s Investment Advisory Contract. The annual fees are negotiable and paid in arrears
    on a quarterly basis (calendar quarter).

    Unless instructed by the client, KC will aggregate asset amounts in accounts from the client’s same
    household to determine the advisory fee for all accounts. KC would do this, for example, when
    managing accounts on behalf of the client’s minor children, individual or joint accounts for a
    spouse/partner, and/or other types of related accounts. This consolidation practice is designed to
    allow the benefit of an increased asset total, which could potentially cause account(s) to be
    assessed a lower advisory fee.

    There is a minimum Investment Management fee of $10,000 annually; this account minimum can
    be waived at the discretion of KC.

    Advisory fees are directly debited from client accounts that are under KC’s management. An
    average of the daily balance in the client’s account throughout the billing period is used to
    determine the market value of the assets upon which the advisory fee is based.
    The client may direct KC to debit the quarterly fee from a specific account of their choosing that
    is under KC’s management (for example: Joint Account, Non-Qualified Account, specific cash
    account, etc.). This will be agreed upon and noted in the Investment Advisory Contract.
    Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee based
    on the amount of time in the billing period. An account may be terminated with written notice
    at least 15 calendar days in advance. Since fees are paid in arrears, no rebate will be needed
    upon termination of the account.

The final, negotiable fee schedule is attached as Exhibit I of the Investment Advisory Contract.
Clients may terminate the agreement without penalty for a full refund of KC's fees within five
business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the
Investment Advisory Contract generally with 15 days' written notice. For contracts terminated
mid-quarter, clients will be responsible for paying the prorated advisory fee (earned but unpaid),
which will be equal to the daily rate* times the number of days in the quarter up to and including
the effective date of termination. (*The daily rate is calculated by dividing the annual asset-based
fee by 365).

     Selection of Other Advisers Fees
     KC may direct clients to third-party investment advisers. KC will be compensated via a fee share
     from the advisers to which it directs those clients. The fees shared are negotiable and will not
     exceed any limit imposed by any regulatory agency. The notice of termination requirement and
     payment of fees for third-party investment advisers will depend on the specific third-party
     adviser selected.

     The timing, frequency, and method of paying fees for selection of third-party managers will
     depend on the specific third-party adviser selected and will be disclosed to the client prior to
     entering into a relationship with the third-party adviser.

     Third Party Fees
     Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees,
     mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and
     expenses charged by KC. Please see Item 12 of this brochure regarding broker-
     dealer/custodian.

     Neither KC nor its supervised persons accept any compensation for the sale of securities or
     other investment products, including asset-based sales charges or service fees from the sale of
     mutual funds.

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

            •   Individuals
            •   High-Net-Worth Individuals
            •   Charitable Organizations
            •   Corporations or Business Entities
    There is a minimum account size of $500,000 for Investment Management, which can be waived
    at the discretion of KC.