Lunt Capital Management Inc

Item 5.      Fees and Compensation

Sub-Advisory Services
Our annual fee for sub-advisory services will typically be up to 0.75% of assets under our
management.

Model Portfolio Services
Our annual fee for model portfolio services will typically be up to 0.75% of assets allocated to the
model/strategy maintained by our firm.

401k Plan Model Services and Consulting
Our annual fee for 401k plan model services and consulting will typically be up to 1.00%.

Portfolio Management Services and Model Portfolio Management Services
Our annual fee for portfolio management services and model portfolio management services will
typically range from 0.50% to 1.00% of assets under our management.

Index Provider for ETFs
LCM is the index provider for ETFs and receives a fee for providing this service. While the ETFs are
available to all investors, including LCM Clients, LCM only invests in the ETFs for those Clients for
whom the ETFs are suitable and that meet the client’s investment objectives. LCM does not charge
a management fee on the Client assets in the ETFs. The fee that LCM receives for providing this
service is based on total assets in the ETFs, and LCM Client assets are included in that total. The
fee received by LCM for providing this service is typically lower than the Client management fee.
LCM may charge a management fee on these ETFs in accounts for which LCM acts as the third-
party investment manager for other financial advisors.

Other Advisory Services
LCM’s fee for consulting, investment research, and tactical signals varies by financial professional
and scope of work. The fee may include compensation based on assets, a subscription fee, or a
flat fee.

Fees in General
LCM will either directly debit client accounts, invoice clients, or receive a fee directly from advisers
or their firms who calculate and deduct fees from client accounts (as specifically agreed with each
client by the specific adviser). These fees are typically charged quarterly in arrears at the beginning
of each calendar quarter based upon the value (market value or fair market value in the absence
of market value), of the client's account at the end of the previous quarter (pro-rated for additions
and withdrawals), based upon the average daily balance, or based upon the value of the account
on the last trading day as determined by the applicable advisory agreement. In some cases, as
specifically agreed with each client, these fees will be charged monthly and in some cases the fees
may be charged in advance but never exceed $1,200 six months or more in advance.

Fees for all services are negotiable based upon certain criteria (e.g., anticipated future earning
capacity, anticipated future additional assets, dollar amount of assets to be managed, related
accounts, account composition, negotiations with the client, etc.) and may take the form of a flat
monthly, quarterly, or annual fee. Discounts up to full waiver of fees, not generally available to all
our advisory clients, may be offered to family members and friends of LCM and others at the
discretion of LCM.

We may group certain related client accounts for the purposes of determining the account size
and/or annualized fee. Certain legacy client agreements may be governed by fee schedules
different from those listed above. Under no circumstances will we earn fees of more than $1,200
more than six months in advance of services rendered.

Account Termination
Clients may terminate their agreement by contacting LCM at our principal place of business during
business hours. Upon termination of any account, any earned, unpaid fees will be due and payable.
Agreements cannot be assigned or transferred without prior written permission.

ETF, ETN, Fund, and Partnership Fees and Expenses
All fees paid to our firm for investment advisory services are separate and distinct from the fees
and expenses charged by ETFs, ETNs, Funds, and Partnerships to their shareholders or limited
partners. These fees may include a management fee, other fund expenses, and a possible
distribution fee. A client may be able to invest in an ETF, ETN, Fund, or Partnership directly, without
the services of our firm. In that case, the client would not receive the services provided by us which
are designed, among other things, to assist the client in determining which ETFs, ETNs, Funds, and
Partnerships are most suitable to each client's financial condition and objectives. Accordingly, the
client should review both the fees charged by the ETFs, ETNs, Funds, and Partnerships and the
fees charged by us to fully understand the total amount of fees to be paid by the client and to
thereby evaluate the value of the advisory services being provided.

Brokerage and Custodial Fees
In addition to advisory fees paid to our firm, clients will also be responsible for all transaction,
brokerage, trade-away, and custodial fees incurred as part of their account management. See

Item 7.      Types of Clients

Our firm generally provides advisory services to advisory firms, model portfolio providers, advisers
associated with a Broker-Dealer, 401k plans, individuals, pension and profit-sharing plans, trusts,
estates or charitable organizations, corporations, or other business entities.

We do not currently impose any minimum annual fees or account minimums. However, in certain
advisory relationships, minimum account size restrictions exist typically ranging from $25,000 to
$100,000.