Newbury Capital Management LLC

Item 5: Fees and Compensation

    How We Are Compensated for Our Advisory Services

    Asset Management:

                         Market Value of Assets      Annual Percentage of Assets Charge

                     Common Stock Fee Schedule
                         Under $1,000,000                            1.500%
                        $ 1,000,000 and up                           1.000%

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                     Fixed Income Fee Schedule:
                            Up to $999,000                             1.000%
                       $1,000,000 - $2,499,000                         0.750%
                       $250,000 to $499,999.99                         0.625%
                          $5,000,000 and up                            0.500%

                      Mutual Fund Fee Schedule                Equity        Fixed Income
                             1st $100,000                     1.500%           1.000%
                             2nd $100,000                     1.375%           0.875%
                             3rd $100,000                     1.250%           0.750%
                         4 $100,000 and up
                          th                                  1.000%           0.500%

    Our firm’s fees are billed on a pro-rata annualized basis quarterly in advance based on the value of
    your account on the last day of the previous quarter. Unless otherwise noted in writing, our firm bills
    on cash. Fees are generally not negotiable and will be deducted from your account. Clients will not
    receive a refund on any assets that are withdrawn within a quarter. Client deposits made within a
    quarter will be charged a prorated fee at our firm’s discretion. As part of this process, the client is
    made aware of the following:
        a) The client’s independent custodian sends statements at least quarterly showing the market
            values for each security included in the Assets and all account disbursements, including the
            amount of the advisory fees paid to our firm;
        b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our
            firm will send an invoice directly to the custodian; and
        c) If our firm sends a copy of our invoice to the client, legend urging the comparison of
            information provided in our statement with those from the qualified custodian will be
            included.

    Retirement Plan Consulting:

    Our Retirement Plan Consulting services are billed on an hourly or flat fee basis or a fee based on the
    percentage of Plan assets under management. The total estimated fee, as well as the ultimate fee
    charged, is based on the scope and complexity of our engagement with the client. The maximum
    hourly fee to be charged will not exceed $250. Our flat fees range from $750 to $10,000. Fees based
    on a percentage of managed Plan assets will not exceed 1.50%. The fee-paying arrangements will be
    determined on a case-by-case basis and will be detailed in the signed consulting agreement.

    Other Types of Fees & Expenses

    Clients will incur transaction charges for trades executed in their accounts. These transaction fees
    are separate from our fees and will be disclosed by the firm that the trades are executed through.
    Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction fees for U.S. listed equities and
    exchange traded funds. Also, clients will pay the following separately incurred expenses, which we
    do not receive any part of: charges imposed directly by a mutual fund, index fund, or exchange traded
    fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund
    expenses). Our firm does not receive a portion of these fees.

    Termination & Refunds

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    We charge our advisory fees quarterly in advance. In the event that you wish to terminate our
    services, we will refund the unearned portion of our advisory fee to you. You need to contact us in
    writing and state that you wish to terminate our services. Upon receipt of your letter of termination,
    we will proceed to close out your account and process a pro-rata refund of unearned advisory fees.

    Commissionable Securities Sales

    We do not sell securities for a commission. In order to sell securities for a commission, we would
    need to have our associated persons registered with a broker-dealer. We have chosen not to do so.

Item 7: Types of Clients and Account Requirements

    We have the following types of clients:
       • Individuals and High Net Worth Individuals;
       • Trusts, Estates or Charitable Organizations;
       • Pension and Profit Sharing Plans;
       • Corporations, limited liability companies and/or other business types

    Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging
    us.