Maguire Investments LLC

Fees and Compensation
    Description

         Maguire Investments charges fees based on the size or value of the account. The
         standard fee is 1.00% on the value of the account. We negotiate fees based on a
         number of factors which include size of account, required meeting schedule and
         complexity of the investment strategy implemented.

    Fee Billing

         Fees can either be deducted from client accounts or billed directly to the client.
         Clients may select either method. Clients are typically billed quarterly in advance and
         advised in writing at the beginning of the relationship that they may terminate our
         services on any quarterly billing date. Should a relationship terminate during a
         quarterly period, clients may obtain a refund. The refund will be prorated based on
         the number of days the account was managed during the quarter in which the
         relationship was terminated.

         In addition to Maguire Investments’ management fees, clients pay commissions or
         transaction fees to their broker or custodian, along with exchange fees. Certain
         accounts, such as trust accounts that require a corporate trustee, incur a custody fee,
         while standard brokerage accounts are typically free from custody fees. Mutual funds
         often charge multiple fees, including management fees and general expenses of the
         fund. This fee is charged on top of the Maguire Investments fee for services. For
         additional information, please see page 8 regarding brokerage practices.

         Maguire Investments and its supervised persons do not accept compensation for the
         sale of securities.

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Types of Clients
    Description

        Maguire Investments provides investment advice to individuals, trusts, estates,
        charitable organizations, banks, and pension and profit sharing plans.

Methods of Analysis, Investment Strategies and Risk of Loss
    Methods of Analysis & Investment Strategies

        Maguire Investments uses multiple methods to analyze potential investments
        including fundamental, technical and cyclical or trend analysis.
        Our fundamental analysis relies heavily on the review of a potential investment’s
        financial statements. Maguire Investments focuses on earnings both from a nominal
        level and relative to previous periods. At that point, the firm relates perceived
        earnings power to the price of the stock in the marketplace. That price/earnings ratio
        plays a key role in determining whether a stock is trading above or below fair value.
        Dividend policy and book value also play a role in determining the correct price for a
        stock.

        Our technical analysis plays a relatively small role in determining whether to
        purchase or sell a stock. Rather, it is used as a timing indicator in order to avoid
        buying or selling at a weak point for any particular stock.

        Maguire Investments’ cyclical or trend analysis plays a key role in discovering
        companies that previously were undiscovered or have been left behind due to
        previous poor performance. The firm continuously analyzes the economy and looks
        for growing trends or cyclical changes that favor certain industries. This process
        produces a list of companies that potentially suit client portfolios, assuming they pass
        the fundamental test as well.

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    Risk of Loss

        All investment programs have certain risks that the investor will bear. Maguire
        Investments’ investment approach keeps the risk of loss in mind. Clients face the
        following investment risks:
            ●​ Interest-rate Risk: Fluctuations in interest rates may cause investment prices to
               fluctuate. For example, when interest rates rise, yields on existing bonds
               become less attractive, causing their market values to decline.
            ●​ Market Risk: The price of a security, bond, or mutual fund may drop in
               reaction to tangible and intangible events and conditions. This type of risk is
               caused by external factors independent of a security’s particular underlying
               circumstances. For example, political, economic and social conditions may
               trigger market events.
            ●​ Inflation Risk: When any type of inflation is present, a dollar today will not
               buy as much as a dollar next year, because purchasing power is eroding at the
               rate of inflation.
            ●​ Currency Risk: Overseas investments are subject to fluctuations in the value
               of the dollar against the currency of the investment’s originating country. This
               is also referred to as exchange rate risk.
            ●​ Reinvestment Risk: This is the risk that future proceeds from investments may
               have to be reinvested at a potentially lower rate of return (i.e. interest rate).
               This primarily relates to fixed income securities.
            ●​ Business Risk: These risks are associated with a particular industry or a
               particular company within an industry. For example, oil-drilling companies
               depend on finding oil and then refining it, a lengthy process, before they can
               generate a profit. They carry a higher risk of profitability than an electric
               company, which generates its income from a steady stream of customers who
               buy electricity no matter what the economic environment is like.
            ●​ Liquidity Risk: Liquidity is the ability to readily convert an investment into
               cash. Generally, assets are more liquid if many traders are interested in a
               standardized product. For example, Treasury Bills are highly liquid, while real
               estate properties are not.
            ●​ Financial Risk: Excessive borrowing to finance a business’ operations
               increases the risk of profitability, because the company must meet the terms of
               its obligations in good times and bad. During periods of financial stress, the
               inability to meet loan obligations may result in bankruptcy and/or a declining
               market value.

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