LEEB Capital Management Inc

Item 5. Fees and Compensation
LCM believes that our annual fees are reasonable in relation to: (1) services provided and (2) the
fees charged by other investment advisers offering similar services/programs. However, our
annual investment advisory fee may be higher than that charged by other investment advisers
offering similar services/programs.

LCM may negotiate advisory fees at its discretion based on the complexity of the client's
situation, the relationship of the client with the investment adviser representative, and the total
amount of assets under management for the client. As a result, clients with similar assets can have
differing fee schedules and pay different fees. In general, the annual fees for LCM’s advisory
services are as follows:

1. Retail Growth Accounts

Up to $500,000.00:         1.50%
Over $500,000.00:          1.00%

2. Institutional Growth Accounts

$5,000,000 to $10,000,000:       0.90%

$10,000,001 to $20,000,000:     0.85%
$20,000,001 to $25,000,000:     0.80%
$25,000,001 to $50,000,000:     0.75%
Over $50,000,000:               Negotiable

3. Income and Growth Accounts

Accounts are charged 1.0%.

4. Peak Resources and Energy Accounts

Accounts are charged 2.0%.

LCM charges a different fee rate or schedule based upon asset classes (e.g., equities, fixed
income) or investment product types (e.g., mutual funds, ETFs, stocks and bonds) invested in the
client’s account. This creates a conflict of interest in that there is an economic incentive for LCM
and its investment adviser representatives to recommend certain asset classes or investment
product types which have a higher fee rate or schedule compared to other asset classes or
investment product types with a lower fee rate or schedule. LCM has taken steps to manage its
conflict of interest arising from its use of different fee rates/schedules through its code of ethics,
whereby LCM and its investment adviser representatives will not exercise investment discretion
with respect to changing asset classes or investment product types and will only recommend the
change of asset classes or investment products when in the best interest of the client and without
regard to the financial interest of LCM.

Clients may choose to be invoiced for the advisory fees or have the advisory fees deducted from
their advisory accounts. Annual fees are divided and prepaid on a quarterly basis for the ensuing
three-month period. The quarterly fee for a given account is calculated based on the market value
of that account on the final day of the preceding quarter. For example, fees for the April-to-June
quarter for an account are calculated based on that account’s ending market value on March 31.
Fees are refundable on a pro-rata basis, in the event of termination of the advisory contract by the
client.

If fees are deducted from your account, you must authorize the qualified custodian(s) of your
account to deduct fees from your account and pay such fees directly to LCM.

You should review your account statements received from the qualified custodian(s) and verify
that appropriate investment advisory fees are being deducted. The qualified custodian(s) will not
verify the accuracy of the investment advisory fees deducted.

If you pay fees directly to our firm via a billing invoice, fees are due upon your receipt of the
invoice sent directly to you. The billing notice will detail the formula used to calculate the fee and
the time period covered.

Brokerage expenses and/or transaction ticket fees charged by your qualified custodians are billed
directly to you by the qualified custodians. LCM does not receive any portion of such expenses or
fees from you or the qualified custodians. Moreover, LCM recommends open-ended, closed-end,
exchange traded funds (“ETFs”) and exchange traded notes (“ETNs”) in managing clients’

accounts. These funds and notes charge fees that are separate from and in addition to LCM’s
management fee including, but not limited to, mutual fund sales loads, 12b-1 fees and surrender
charges, IRA and qualified retirement plan fees, and charges imposed by the qualified
custodian(s) of your account. Management fees charged by LCM are separate and distinct from
the fees and expenses charged by investment company securities recommended to you. A
description of these fees and expenses are available in each investment company security’s
prospectus. LCM does not receive any portion of such third-party expenses or fees.

LCM and our supervised persons do not accept or receive compensation based on the sale of
securities or other investment products such as asset-based sales charges or service fees from the
sale of mutual funds.

Item 7. Types of Clients
LCM provides investment supervisory services to various types of clients, including individuals,
institutions, trusts, pensions, and profit-sharing plans.

There is an investment minimum of $250,000 for new accounts in the Growth and Income &
Growth strategies and $100,000 in the Peak Resources and Energy strategy. However, at its
discretion, LCM may waive this investment minimum.