Lewis Capital Management LLLP

Fees and Compensation
All of LCM’s revenues, which are based on a percentage of assets, are derived from
investment management services.

LCM’s annual fee is 1% of the total value of a client’s portfolio, billed quarterly in advance;
however, all fees are negotiable.

Other fees may be incurred by the client as part of using a brokerage service, including
custodian fees, mutual fund fees and transactions costs associated with equity and
mutual fund trading. See Brokerage Practices on p. 5 for further detail.

If a client contract is terminated before the end of the billing period, a refund of the pre-
paid fee will be sent by check to the client. The refund is calculated by taking the most
recently billed fee and dividing it by the number of days in the billing period and then
multiplying that amount by the number of days remaining in the billing period.

LCM does not accept compensation for the sale of securities or other investment
products, nor does it charge any other service fees.

Performance-Based Fees and Side-By-Side Management
LCM does not participate in either of these fee structures.

Types of Clients
LCM provides investment advice to individuals and trusts. Although LCM’s business
model is directed at accounts with a $5 million minimum, it does not have a minimum
account size.

Methods of Analysis, Investment Strategies and Risk of Loss
A. Investment analysis emphasizes the selection of companies with a long history of
   earnings and dividend growth. Companies are selected such that portfolios include all
   economic sectors. Where tax brackets are relatively low, indexed stock funds are
   frequently used. For fixed income, institutional bond funds are used since tax savings
   from using individual bonds are minimal and the cost of buying and selling individual
   bonds is more expensive than buying a fixed income fund for the account sizes LCM
   manages.

   As described above, different aspects of these strategies are used based upon a
   client’s tolerance for principal volatility, as dictated by both emotional and cash flow
   needs.

B. Since LCM’s investment strategy emphasizes large-cap US domiciled stocks, the
   primary risk is general panic by investors, resulting in a possible reduction of over 60%
   in the broad stock market, as seen in 2008. This risk is addressed by accompanying
   the holding of the aforementioned stocks alongside investment-grade institutional
   bond funds for stability.

C. Emphasis on large-cap domestic stocks, institutional bond funds and indexed
   mutual funds include the risks associated with the general stock and bond markets.
   LCM attempts to reduce these risks as described in the preceding paragraph.