Moreton Asset Management LLC

Item 5          Fees and Compensation

The annualized fee for managed accounts is calculated as a percentage of assets under management, according to
the following tiered fee schedule:

Moreton Asset Management ADV 2A                                                                      Page 4 of 19

Assets Under Management                                 Annual Fee
  $0 to $10 Million                                       0.25%
  $10 to $20 Million                                      0.20%
  $20 to $40 Million                                      0.175%
  $40 to $100 Million                                     0.15%
  Over $100 Million                                       Negotiated

MAM associates do not receive compensation (commissions) generated from security related transactions.

Fees for accounts are negotiable based on factors such as referring source, the type of client (corporation,
municipality, individual, etc.), the complexity of the client's situation, the composition of the client's account, pre-
existing relationships, related accounts, competitive environment, market conditions, the potential for additional
account deposits, custody location, the total amount of client assets under management, and other reasons MAM
deems appropriate. The minimum opening account size is $3 million. However, this is subject to management
discretion. MAM may open an account that is smaller than $3 million for reasons it deems appropriate, including,
but not limited to: account’s potential for future growth, other existing accounts, access to a new market, etc.

Fees for MAM accounts are calculated and charged monthly, in arrears. Fees are debited directly from the client
account assets, as described in the advisory contract. Clients must give permission to their Custodian to allow
such an arrangement. Fees are based on the average daily balance of the assets under management.

MAM may also enter an advisory relationship with a client and/or bill/invoice the client directly for advice
rendered on an hourly basis. The rate at which MAM bills for such arrangements is detailed in each individual
advisory agreement.

Outside of MAM’s advisory fee, Clients may have to pay custodial fees, brokerage fees, investment management
fees of underlying funds and other transaction fees related to their investment.

Additionally, MAM occasionally charges nominal fees for teaching classes and/or educational seminars, often
associated with an association or organization, and/or in connection with a conference or symposium.

Moreton Asset Management ADV 2A                                                                            Page 5 of 19

Item 7          Types of Clients

MAM provides advisory and asset management services to the following types of clients:

        Individuals (high net worth individuals, accredited investors, business owners);
        Trusts;
        Estates or charitable institutions;
        Corporations and business entities;
        State and municipal government entities;
        Credit unions and banks;
        Insurance companies;
        Universities, hospitals, and other non-profits; and
        Other entity types as deemed appropriate by MAM

Typically, a $3 million minimum is required to open an account.

Moreton Asset Management ADV 2A                                                             Page 7 of 19