Newport Investment Advisors Inc

Item 5 – Fees and Compensation

 Fees are charged in advance. Fees for NIA services will be determined on a basis of Managed
 Account assets multiplied by the appropriate per annum percentage based on the fee schedule
 shown below. The quarterly amount will be one-fourth the annual rate. The fee will be based upon
 the most recent quarter ending valuation reflecting market prices at the end of that quarter. NIA's
 fees for services provided will be governed by the following fee schedule:

 $ 0 to $999,999.99             @ 1.00%
 $1,000,000 to $4,999,999.99    @ 0.75%
 $5,000,000 to $9,999,999.99    @ 0.60%
 $10,000,000.00 or greater      @ negotiable

 Fees are customarily deducted from the client account. Clients may request to be invoiced directly
 instead.

 Performance based fees are available by negotiation. Performance based fees are not available to
 clients in the state of Wisconsin. The state of Wisconsin does not allow performance-based fees.

 NIA does not share in the capital gains of a client account.

 All fees are subject to negotiation. Some negotiable circumstances may include charitable
 portfolios or situations in which competitive fees are a factor in the selection of an advisor.

 Upon termination, any prepaid fee is refundable on a pro-rata basis for the period unearned.
 Certain clients of the NIA will be former clients of NIA shareholder's former employer. In such
 cases, fees charged to those Managed Accounts will be based upon that former employer's fee
 schedule then in effect.

 In those circumstances where NIA serves as a sub-advisor, NIA's fee is determined by contract
 with the other investment advisor. NIA will obtain assurance from the advisor that it is properly
 registered in states that NIA is engaged to sub-advise.

 Services offered are primarily in the form of a reactive allocation service. Reallocations may be
 performed on a stock and/or bond mutual fund(s). NIA may suggest mutual fund families to be
 used. Client accounts typically invest in ETFs, no-load, or load-waived mutual funds. For defensive
 purposes, client account may be positioned to hold cash or money market funds. Trade decisions
 are based upon proprietary decision models. Such decision models include technical and
 fundamental indicators such as moving averages, collars, yield curve and other factors.

 Since most accounts will involve the purchase of mutual fund shares, ETFs, CEFs or variable
 annuities, the client pays a direct advisory fee to NIA and an indirect advisory fee to the advisor to

Newport Investment Advisors, Inc.                                                        216.514.5151

 the funds, which reduces the net asset value of the funds' shares. Therefore, NIA's clients pay two
 levels of advisory fees for the management of their assets. As such, the total advisory fees paid may
 exceed that which may be charged by other advisors. The total fees may also be lower than other
 advisors.

 Newport Investment Advisors, Inc.’s fees are exclusive of brokerage commissions, transaction fees,
 and other related costs and expenses which shall be incurred by the client. Clients may incur
 certain charges imposed by custodians, brokers, third party investment advisors and other third
 parties such as fees charged by managers, custodial fees, deferred sales charges/early redemption
 fees, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage
 accounts and securities transactions. Mutual funds and exchange traded funds also charge internal
 management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions
 are exclusive of and in addition to NIA’s fee.

 NIA does not provide financial planning.

 Item 12 further describes the factors that NIA considers in selecting or recommending broker-
 dealers for client transactions and determining the reasonableness of their compensation (e.g.,
 commissions).

Item 7 – Types of Clients

 Newport Investment Advisors, Inc. provides or offers to provide portfolio management services to
 individuals, high net worth individuals, corporate pension and profit-sharing plans, Taft-Hartley
 plans, unified managed accounts (UMA), charitable institutions, foundations, endowments, private
 investment funds, and trust programs.