Malvern Capital Management LLC

Item 5: Fees and Compensation
Method of Compensation and Fee Schedule

Financial Planning Fees
The rate for Comprehensive Financial Planning Services is $2,500.
Financial Planning Fees require a $1,200.00 initial deposit paid in advance. These fees and
terms are negotiable on a case-by-case basis at the discretion of MCM. The fees to be paid
will be outlined in each client’s written agreement. The delivery date of the Financial Plan will
be based in part on the date all required pertinent information is received and will be mutually
agreed upon with each client. The client may terminate the Agreement at any time before the
delivery of the Financial Plan for a full refund.
Services are completed and delivered within sixty (60) days, contingent upon timely delivery
of all required documentation. MCM reserves the right to waive a portion of the fee should the
Client implement the plan through MCM.

Financial Consulting Service Fees
MCM is compensated for our Financial Consulting Services by receiving fees from clients
based on an hourly rate of $500 or a single fixed fee that typically can range from $1,000 to
$100,000.
FCS Fees are paid in arrears. The hourly fee rate is negotiable on a case-by-case basis at
the discretion of MCM. A single fee rate is negotiated on a case-by-case basis with each
client and is based on the scope of the services to be provided by MCM. The hourly rate or
single fixed fee to be paid, and terms will be outlined in each client’s written agreement. A
client may terminate the Financial Consulting Service at any time.

Investment Management Fees:
MCM offers discretionary direct asset management services to advisory Clients. MCM is
compensated for our investment management services by receiving fees from clients based
on a percentage of assets under management per the following tiered rate schedule:

Total Assets Under Management             Annual Advisor Fee
Up to $500,000                                 1.25%
$500,001 to $1,000,000                         1.00%
$1,000,001 to $2,000,000                       0.85%
$2,000,001 to $3,000,000                       0.70%
$3,000,001 to $5,000,000                       0.60%
$5,000,001 to $10,000,000                      0.50%
Over $10,000,000                               0.25%
The minimum annual fee is $5,000. This fee will not exceed the 3% safe harbor.
Investment Management Fees are either charged quarterly in advance, based upon the
market value of the assets being managed by MCM on the last day of the previous billing
period, or the initial asset value deposit for a new account or billed quarterly, in arrears, and
are based on the amount of assets under management on the last day of the prior calendar
quarter (“Valuation Date”) as valued by the Client’s Custodian. If margin is utilized, the fees
will be billed based on the net asset value of the account. Significant contributions or
withdrawals of more than 5% of assets under management to or from the Client’s account
during any calendar quarter are prorated daily for the period such funds were actually in the
Client’s account. The assets under management of the Client’s account on the Valuation
Date shall be correspondingly increased or decreased, as the case may be, for purposes of
calculating the Management Fee for the Quarter. In the event of early termination, the client
will receive reimbursement of prepaid, unearned fees.
Fees and terms are negotiable on a case-by-case basis at the discretion of MCM, resulting in
some clients being charged fees that are lower than the fee listed above. Fees are
calculated in accordance with the fee schedule outlined in each client’s written agreement.
Legacy clients resulting from a merger, acquisition, assignment, or any other transfer of
ownership from another advisory firm to Malvern Capital Management may experience higher
fees than those disclosed in our standard fee schedule. Their accounts also may not be
eligible for householding.

Sub-Advisor Services (SAS)
Clients having their accounts managed by an independent Sub-advisor pay MCM Investment
Management Service fee plus the Sub-advisor fee. In certain circumstances, you will pay a
higher Investment Management Service fee if a Sub-advisor is used. The total Investment
Management Service fee plus Sub-advisor fee shall not exceed 2.00% per year. Sub-advisor
fees are deducted from the Client’s account with MCM’s fee as outlined above. The Sub-
advisor’s fee is calculated in the same manner.

Retirement Plan Services Fees
MCM is a fiduciary under ERISA with respect to investment management services and
investment advice provided to ERISA Plan Clients. As such, MCM is subject to specific duties

and obligations under ERISA and the IRC that include, among other things, restrictions
concerning certain forms of compensation.

The fees described below for both Participant Directed Plans and Non-Participant Directed
Plans are payable quarterly or monthly in arrears as agreed to under the investment
management agreement between MCM and the ERISA Plan Client.

Either MCM or the ERISA Plan Client can terminate the investment management or advisory
agreement at any time, without penalty, by sending the other party 30 days' prior written
notice. Both parties remain responsible for obligations arising under any transactions initiated
before the agreement was terminated. MCM is entitled to a fee, prorated for the number of
days in the billing period before the effective date of termination, based on the market value
of the included assets on the effective date of termination.

3(38) Investment Management for Participant-Directed Plans:
The MCM fee for investment management services provided to ERISA participant-directed
plans is calculated as of the last business day of each calendar quarter or month by charging
the following tiered fee schedule, based on the annual rate, subject to a minimum fee of
$5,000 per year:
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Item 7: Types of Clients
Description
MCM currently provides investment management, financial planning, and financial consulting
services to a variety of different types of clients, including individuals and high-net-worth
individuals. MCM also focuses its marketing efforts on attracting pension and profit-sharing
plans, trusts, estates, endowments, foundations, charitable organizations, corporations, and
other registered investment advisory firms. Account Minimums
MCM requires a minimum of $500,000 to open and maintain an account. In certain instances,
the minimum account size may be lowered or waived.