McCulley Financial Group LLC

Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
   MFG bases its fees for advice on a percentage of assets under management, hourly
   charges and fixed fees for advice (not including subscription fees for advice).
  ASSET MANAGEMENT
  MFG offers discretionary and non-discretionary direct asset management services to
  advisory clients.

  Fees for advice will be based on a percentage of Assets Under Management as
  follows:

       Assets Under Management                   Annual Fee              Monthly Fee
              Up to $500,000                        1.00%                   .083%
          $500,000 to $1,000,000                    0.90%                   .075%
         $1,000,000 to $2,000,000                   0.80%                   .067%
         $2,000,000 to $5,000,000                   0.70%                   .058%
        $5,000,000 to $10,000,000                   0.60%                   .050%
        $10,000,000 to $25,000,000                  0.50%                   .042%
        $25,000,000 to $50,000,000                  0.40%                   .033%
             Over $50,000,000                       0.30%                 Negotiable

  If any additional services are requested or required by the client beyond those
  describes in the section titled “Types of Advisory Services”, the client may be charged
  at a rate of $250 per hour. These fees for advice will be agreed upon before billing the
  client and the client will receive an estimate of the fees. These hourly fees for advice
  are billed monthly in arrears. The client will be charged to a pro rata fee for advice for
  the days service was provided in the final quarter.
  Fees for advice are billed monthly in arrears based on the amount of assets managed
  as of the close of business on the last business day of previous month. Monthly
  advisory fees for advice deducted from the clients' account by the custodian will be

                               McCulley Financial Group, LLC

reflected in a provided fee invoice as fees are withdrawn. Lower fees for advice for
comparable services may be available from other sources. Clients can terminate their
account within five (5) business days of signing the Investment Advisory Agreement
for a full refund. Clients may terminate advisory services with thirty (30) days written
notice. Client will be entitled to a pro rata fee for advice for the days service was
provided in the final month. Client shall be given thirty (30) days prior written notice of
any increase in fees for advice.

FINANCIAL PLANNING
Based on the services outline in the Section “Types of Advisory Services”, fees for
Financial Plans are as follows:
         Service Level          1 / Bronze            2 / Silver      3 / Gold
          Monthly Fee           $250/mo or           $500/mo or     $1000/mo or
             Assets        $500k+ in assets       $1m+ in assets   $2m+ in assets

If any additional services are requested or required by the client, the client will be
charged at an hourly rate of $250.

PAST DUE ACCOUNTS
Interest at 10% per year will be charged on balances more than 60 days past due.
CORPORATE RETIREMENT PLANS, 401(K), PROFIT SHARING, AND DEFINED
BENEFIT CONSULTING
MFG offers asset management to corporate retirement plans, 401(k), profit sharing and
defined benefit consulting. Fees for advice will be based on a percentage of Assets
Under Management as follows:

        Assets Under Management                   Annual Fee            Monthly Fee
             Up to $1,000,000                        1.00%                 0.083%
         $1,000,000 to $5,000,000                    0.75%                 0.063%
        $5,000,000 to $10,000,000                    0.70%                 0.058%
       $10,000,000 to $15,000,000                    0.60%                 0.050%
       $15,000,000 to $20,000,000                    0.50%                 0.042%
       $20,000,000 to $25,000,000                    0.40%                 0.033%
       $25,000,000 to $50,000,000                    0.30%                 0.025%
       $50,000,000 to $100,000,000                   0.20%                 0.017%
            Over $100,000,000                      Negotiable            Negotiable

If any additional services are requested or required by the client beyond those
describes in the section titled “Types of Advisory Services”, the client may be charged

                                McCulley Financial Group, LLC

  at a rate of $250 per hour. These fees for advice will be agreed upon before billing the
  client and the client will received an estimate of the fees. These hourly fees for advice
  are billed monthly in arrears. The client will charged a pro rata fee for advice for the
  days service was provided in the final quarter.
       Service Level          1 / Bronze           2 / Silver               3 / Gold
        Monthly Fee          $500/mo or           $1000/mo or           $3000/mo or
           Assets          $1m+ in assets        $3m+ in assets       $10m+ in assets

  Fees for advice are billed monthly in arrears based on the amount of assets managed
  as of the close of business on the last business day of previous month. Monthly
  advisory fees for advice deducted from the clients' account by the custodian will be
  reflected in a provided fee invoice as fees are withdrawn. Lower fees for advice for
  comparable services may be available from other sources. Clients can terminate their
  account within five (5) business days of signing the Investment Advisory Agreement
  for a full refund. Clients may terminate advisory services with thirty (30) days written
  notice. Client will be entitled to a pro rata fee for advice for the days service was
  provided in the final month. Client shall be given thirty (30) days prior written notice of
  any increase in fees for advice.
Client Payment of Fees
...

Item 7: Types of Clients
Description
   MFG generally provides investment advice to individuals, high net worth individuals,
   pension and profit sharing plans.
   Client relationships vary in scope and length of service.
Account Minimums
  MFG does not require a minimum to open an account.