Kirtland Hills Capital Management LLC

Item 5 – Fees and Compensation

Investment Management Fees              Annual Fee (Flat Fee Rate)
                                           1.2% (subject to negotiation in certain
                                           circumstances)

      Kirtland Hills Capital Management | LLC
Kirtland Hills Capital Management, LLC is compensated on a percentage of client assets under
management. A schedule of the Firm’s general management fees is set out above, but different
management fees may be negotiated in certain circumstances, and the fee schedule included in
the client’s Investment Advisory Agreement will govern. Client accounts are managed on a
discretionary basis with fees calculated and deducted from client accounts monthly in arrears.
The assets under management at the end of each calendar month will be multiplied by the
applicable annual rate for that client, and the result will be divided by twelve. If an account is
initiated other than on the first day of a month, the fee for the partial month will be prorated
on a daily basis and calculated as of the end of the partial month. Additionally, clients may
terminate their contracts with two weeks written notice without penalty. If an account is
terminated other than at the end of a month, the advisory fee for the partial month will be
prorated on a daily basis. All advisory fees are withdrawn directly from the client’s account
with written authority.

KHCM, LLC fees are exclusive of brokerage commissions, transaction fees and other related
expenses that are to be paid by the client. See “Item 12—Brokerage Practices.” Clients may
also incur charges from custodians, brokers and third parties such as, wire transfer fees,
electronic fund transfer fees and taxes on brokerage accounts. Exchange traded funds and
mutual funds also charge management fees which are disclosed in the fund’s prospectus.
These fees and charges are exclusive of and in addition to KHCM, LLC fees. Kirtland Hills Capital
Management, LLC accepts no commissions for any financial product sale. KHCM, LLC is only
compensated by fees paid to the Firm by the client, generally by deduction from the client’s
account.

Item 7 – Types of Clients

Kirtland Hills Capital Management, LLC provides Investment Advisory Services primarily to
individuals, high net worth individuals, families and small businesses. There is no specific
minimum account size required by KHCM, LLC, but the Firm may decline to accept an account
for any reason, including the size of the account.