Kevin E Vandenberg LLC

Item 5: Fees and Compensation

Compensation
AIM bases its fees on a percentage of assets under management. AIM’s fee schedules
are described below.
Compensation – Investment Management Services
The annual fees for AIM asset management services are:
       For asset totals under $1,000,000
   •   1.75% for assets under $100,000
   •   1.25% for asset totals of $100,000 to 1,000,000

       For asset totals over $1,000,000
   •   1.00% of the first $2,000,000
   •   0.85% of the next $3,000,000 of assets under management
   •   0.75% of the next $5,000,000 of assets under management

Our fee is billed and payable quarterly, in advance, based on the market value of your
account on the beginning of the quarter in which it is billed. If a client leaves during the
quarter in which a fee has already been collected, we may refund the pro-rata share of
the fee “unearned” by AIM for the rest of the quarter if requested by the client in writing.
We may allow accounts of members of the same household to be aggregated for
purposes of meeting our minimum account size or fee. We may allow such aggregation,
for example, where we service accounts on behalf of minor children of current clients,
individual and joint accounts for a spouse, and other types of related accounts.
We will deduct our fee directly from your account through the qualified custodian holding
your funds and securities, but only after you have given our firm written authorization
permitting the fees to be paid directly from your account. There may be some instances
where clients are billed for assets managed that are not held at Charles Schwab. In this
case, clients submit payment quarterly after being billed on those assets. Further, the
qualified custodian will deliver an account statement to you at least quarterly. These
account statements will show all disbursements from your account. You should review all
statements for accuracy. Note: existing clients may have been grandfathered in from a
different fee schedule.
General Information on Compensation and Other Fees
In very limited circumstances, fees, account minimums, and payment terms may be
negotiable depending on a client’s unique situation – such as the size of the aggregate
related party portfolio size, family holdings, low cost basis securities, or certain passively
advised investments and pre-existing relationships with clients. Certain clients may pay
more or less than others depending on the amount of assets, type of portfolio, the time
involved, the degree of responsibility assumed, the complexity of the engagement, special
skills needed to solve problems, the application of experience, and knowledge of the

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client’s situation. Lower fees for comparable services may also be available from other
sources.
Custodians charge transaction fees on purchases or sales of stocks and may charge fees
on purchases or sales of mutual funds and certain exchange-traded funds. These
transaction charges are usually small and incidental to the purchase or sale of a security.
The selection of the security is more important than the nominal fee that the custodian
charges to buy or sell the security. More information on brokerage can be found in Item
12.
All fees paid to AIM for investment advisory services are separate and distinct from the
fees and expenses charged by mutual funds and variable annuity sub-accounts to their
shareholders. These fees and expenses are described in each fund’s or sub account’s
prospectus. These fees will generally include a management fee, other expenses, and a
possible distribution fee. If the fund also imposes sales charges, a client may pay an
initial or deferred sales charge, although AIM tends not to use these types of funds.
A client could invest in a mutual fund or sub-account directly, without the services of AIM.
In that case, the client would not receive the services provided by AIM which are
designed, among other things, to assist the client in determining which mutual funds or
sub-accounts are most appropriate to each client’s financial condition and objectives.
Accordingly, the client should review both the fees charged by the funds/sub-accounts
and the fees charged by AIM to fully understand the total amount of fees to be paid by
the client and to thereby evaluate the advisory services being provided.
Generally, we use no load mutual funds and funds with no 12b-1 fees. This eliminates a
potential conflict of interest for using securities that provide remuneration to us, the
adviser.
Clients should note that similar advisory services may (or may not) be available from other
registered investment advisers for similar or lower fees.
Compensation for the Sale of Securities or Other Investment Products
None of our associated persons receive any compensation on behalf of our firm. The only
compensation AIM receives is from our investment fees and financial planning fees. This
practice could present a potential conflict of interest because persons providing
investment advice on behalf of our firm who are insurance agents have an incentive to
recommend insurance products for the purpose of generating commissions.

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Types of Clients
AIM is a Registered Investment Adviser providing advice to individuals, pension and
profit-sharing plans, trusts, foundations, endowments, corporations, and charitable
organizations.
Account Minimums
AIM generally requires a minimum account of $100,000 for investment advisory clients,
although this may be negotiable in limited circumstances. AIM may group certain related
client accounts for the purposes of achieving the minimum account size.
AIM, in its sole discretion, may waive its minimum fee and/or charge a lesser investment
advisory fee based upon certain criteria (e.g., historical relationship, type of assets,
anticipated future earning capacity, anticipated future additional assets, dollar amounts
of assets to be managed, related accounts, account composition, negotiations with
clients, etc.). AIM may also waive the minimum if a client appears to have significant
potential for increasing assets in the future under our management.

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