Norton Capital Management Inc

Item 5 - Fees and Compensation

All fees charged by NCM for advisory services are negotiable and are for advisory services only. Fees paid to NCM do
not include or cover transaction commissions, custodian fees, or other charges (see Item 12 - Brokerage Practices).
Although NCM believes its fees are competitive, clients may be able to obtain similar services at higher or lower

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costs elsewhere. Asset management services fees are based upon the value of assets under the firm’s management.
Fees charged by NCM may be negotiated at NCM’s discretion.

The standard fee rates:
          Equities :
                                   Asset Value              Annual Fee
                          First $2,000,000                     1.00%
                          Next $3,000,000                      0.75%
                          Over $5,000,000                      0.50%

          Fixed Income:
                     Asset Value                            Annual Fee
                          Fixed Assets                       0.50% Flat

In determining whether to negotiate fees, NCM considers a number of relevant factors, including the type of
account, securities held, dollar value of securities, projected nature of trading, nature and scope of individual
advisory services required to properly service the account, and other factors such as the client’s total assets under
management by NCM and whether NCM manages any related accounts (e.g., a client’s family members or other
members of the household). Therefore, clients receiving similar asset management advisory services may be
charged different fees.
All fees due NCM are payable quarterly in advance. The initial fee, which is the fee for the balance of the then-current
calendar quarter, is based on the date the service agreement is signed between NCM and the client and the account’s
asset value on that date. The quarterly fees are based upon the asset value of the account, including accrued interest, on
the last business day of the calendar quarter.
Capital contributions or withdrawals from a client’s account, in an amount greater than $250, will cause a pro-rated
adjustment to the management fee for the benefit of the client in the case of withdrawals and for the benefit of NCM
in the case of contributions.
Fees payable to NCM for asset management services are, with the client’s prior permission, automatically deducted
from the client’s account when due. Clients receive quarterly statements from the custodian of their accounts that
reflect the fees debited from their accounts, and clients are encouraged to confirm the accuracy of the amount debited
against their respective fee schedule. If necessary, NCM will liquidate money market shares to pay the fee and, if
money market shares or cash is not available, other investments may be liquidated. Authorization for NCM to deduct
fees from client accounts is pursuant to a written agreement. Clients may terminate this authorization at any time in
writing.
Either NCM or the client may terminate the agreement at any time with at least 10 days prior written notice to the
effective date of termination. NCM will issue a pro-rata refund of the prepaid fee based on the termination date.
To the extent mutual funds and/or ETFs are included in the assets managed by NCM, clients should be aware that
such funds pay their own internal advisory fees and expenses which affect their reported performance. A description
of these fees and expenses is available in each fund’s prospectus. Depending on the fund, a client may be able to
invest directly in the shares of a fund with lower expenses and without incurring advisory management fees. In
addition, there may be tax effects pertaining to fund share redemptions made by NCM on behalf of clients in taxable
accounts. Redemptions are typically taxable events which may accelerate the recognition of capital gains, and
frequent redemptions may result in short-term, rather than long-term capital gains in taxable accounts.

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Additionally, the fees charged by NCM are exclusive of all custodial and transaction fees paid to custodians,
brokers, or any other third parties. Clients should review all fees charged by NCM, custodians, brokers and others
to fully understand the total amount of fees incurred. NCM does not charge start-up or termination fees.

Item 7 - Types of Clients

NCM primarily serves individuals but offers its investment advisory services to a wide variety of clients, including,
but not limited to, banks or thrift institutions, pension and profit sharing plans, trusts, estates, charitable
organizations, corporations, and other business entities.