Mount Lucas Management LP

5.    Fees and Compensation
     Description

         Mount Lucas charges a management fee that is based on a percentage of
         assets under management for a respective client account. For some
         products, Mount Lucas also charges a performance fee and/or profit
         allocation.

    The management fee is generally charged monthly or quarterly in arrears and
    ranges from an annual rate of 0.18% to 2% of the end-of-month account
    value. The performance fee and/or profit allocation, which is accrued monthly
    and paid annually, semi-annually or quarterly, is generally equal to an annual
    rate of 10% to 25% of the amount by which returns exceed the benchmark
    stated in the respective Limited Partnership Agreement, Limited Liability
    Company Agreement, Offering Memorandum or Investment Management
    Agreement.
    A managed account client can generally terminate its advisory contract at any
    time. Fees are prorated for cancelled contracts.
    Specific fee amounts are negotiated with a respective managed account
    client and set forth the respective Investment Management Agreement.
    Fees attributable to investment funds managed by Mount Lucas are set forth
    in the respective Offering Memorandum, as such may be amended or
    supplemented from time to time.
    Fees are usually deducted from a designated client account to facilitate
    billing. The client must consent in advance to direct debiting of their
    investment account. A client may request to be invoiced and billed fees
    separately and such arrangement is specified in the respective Investment
    Management Agreement.
    Please also refer to the “Performance-Based Fees and Side By Side
    Management” section of this Firm Brochure.

Other Fee Information

    In addition to management and/or performance fees payable to Mount Lucas,
    clients will incur and be responsible for paying brokerage fees and
    commissions in respect of the broker for the client account. The client is
    responsible for selecting its brokerage relationship. Please also refer to the
    “Brokerage Practices” section of this Firm Brochure.
    Investors in a Fund that is managed or sponsored by Mount Lucas are
    charged their pro rata share of brokerage commission, administration fees,
    and operating expenses attributable to their investment in a respective Fund.
    Such fees and expenses are disclosed in the relevant Fund’s Offering
    Memorandum. Please also refer to the “Performance-Based Fees and Side
    By Side Management” section of this Firm Brochure.
    Mount Lucas, in its sole discretion, may waive or amend its minimum fee
    and/or charge different management fees or incentive fee across client
    accounts based upon certain criteria (e.g., historical relationship, type of
    assets, anticipated future earning capacity, anticipated future additional
    assets, dollar amounts of assets to be managed, related accounts, account
    composition, negotiations with clients, etc.).

7.    Types of Clients
     Description

         Mount Lucas provides alternative asset management services and investment
         products to institutional investors, pension plans, trusts, mutual funds and
         high-net-worth individuals.
         Due to the sophisticated and potentially risky nature of the investments
         directed by Mount Lucas, the Firm will accept as clients only those persons or
         entities with the requisite investment knowledge and financial resources.
         An investor in a Mount Lucas-sponsored Fund must be at least an “accredited
         investor,” as defined by SEC Regulation D under the Securities Act of 1933,
         as amended.
         Any client for whom a performance fee and/or allocation is charged must be a
         “qualified client” as such term is defined in Rule 205-3 of the Investment
         Advisers Act, as amended.
         Additionally, certain Mount Lucas Funds require an investor to be a “qualified
         purchaser” as defined under Section 2(a)(51)(A) in the Investment Company
         Act of 1940.
         Clients that seek to establish a managed futures account and investors in
         certain Mount Lucas Funds must also be “qualified eligible persons” as
         defined under CFTC Regulation 4.7.

     Account Size and Investment Minimums

         The initial account size for a managed account client is negotiated with each
         client and set out in the respective Investment Management Agreement.
         The Offering Memorandum for a respective Mount Lucas sponsored Fund
         specifies the applicable minimum investment requirement.