Oarsman Capital Inc

Item 5 - Fees and Compensation

Fees paid to OCI are for OCI investment-advisory services only and are negotiable. Advisory fees paid to OCI
do not include, for example, fees charged by third-party advisors, such as accountants or attorneys, brokerage
commissions, account closing/transfer fees, custodial fees, taxes, separate account investment management
fees charged by Independent Managers and other costs incidental to the purchase and sale of investments. In
addition, transaction costs and other account fees will be charged by brokerage firms in accordance with each
brokerage firm’s commission and account-fee schedule. See Item 12, Brokerage Practices, for additional
information.

In addition to OCI's investment-advisory fee, all mutual funds and exchange-traded funds in which a client's
assets are invested charge their own internal fees and expenses (the funds’ ‘expense ratio’). This expense
ratio represents the percentage of fund assets used to operate the fund, and comprises investment- management
fees, administrative costs, brokerage costs, distribution fees and other operating expenses. Though these
expenses are paid by the fund, they are ultimately borne by clients via a reduction in fund net-asset value. In
most cases, clients can invest directly in MF/ETF shares outside of their account managed by OCI and avoid
incurring OCI’s advisory fee. Clients should consider both OCI’s advisory fee and fund expense ratios (which
are set forth in the prospectus for each fund) when evaluating the total cost of any OCI investment program
or comparing that cost with those of other investment programs.

OCI often purchases commission-free ETFs and no-transaction-fee (NTF)/"no-load" share classes of mutual
funds, which can be purchased and sold without incurring incremental transaction costs. The use of no-
load/NTF funds can be advantageous in volatile market conditions and for clients who make regular
contributions or withdrawals from their accounts, both of which can increase trading activity. No- load/NTF
funds generally have higher ongoing operating expenses (expense ratios) than similar-objective funds
carrying loads and/or transaction fees. Accordingly, clients with larger accounts and those who make
infrequent contributions/withdrawals could find OCI programs more costly than other investment programs.

Transactions made by OCI on behalf of clients can result in tax consequences. For non-tax-deferred (e.g.,
personal, joint and trust) accounts, fund-share redemptions and security sales are taxable events that may
accelerate the recognition of capital gains (and losses); some redemptions/sales may result in short-term,
rather than long- term, capital gains (and losses).

OCI Advisory Fees

Advisory fees are calculated based on the value of investments in a client’s account(s). OCI fees are typically
subject to the following fee schedule. OCI reserves the right to modify its fees under certain circumstances. LRC’s fees
follow a different schedule due to the range of services offered its distinct clientele.

                Assets Under Management                          Annual Rate           Quarterly

                First $500,000                                       1.0%               0.250%
                Next $500,000                                        0.8%               0.200%
                Next $2 million                                      0.7%               0.175%
                Next $2 million                                      0.6%               0.150%
                Over $5 million                                      0.5%               0.125%

Asset-based fees for LRC clients are typically subject to the following fee schedule*:

               Assets Under Management                                        Annualized Fee

               $1.0 million but less than $1.5 million                             0.95%
               $1.5 million but less than $2.5 million                             0.85%
               $2.5 million but less than $4.0 million                             0.75%
               $4.0 million but less than $6.0 million                             0.65%
               $6.0 million but less than $10.0 million                            0.55%
               $10.0 million but less than $20.0 million                           0.50%
               $20.0 million or more                                               0.45%

*Subject to a minimum account size of $1,000,000 (though this may be waived at OCI’s or LRC’s discretion).

Advisory fees are billed in advance, generally on a calendar-quarterly basis at a rate equal to one-quarter of
the annual rate. Fees are based on the market value of the managed account(s) as of the last business day of
the prior quarter. The fee for any period which is less than a full quarter is pro-rated based on the number of
days during the period OCI managed the account. A client will receive a pro-rated refund of prepaid fees by
giving OCI 30 days’ advance written notice of intent to terminate his/her investment- management
relationship (provided such notice is given more than 30 days before the end of a billing period). No
adjustment or refund is made with respect to partial withdrawals during any billing period. With written client
authorization, fees are billed directly to, and debited from, the client’s account(s), unless other arrangements
for payment are requested by the Client. OCI, in its sole discretion, combines the value of accounts for
immediate family members for fee billing purposes.

Most employees of OCI receive investment advisory services from OCI without paying a fee but otherwise
these employee accounts are treated like other client accounts. OCI maintains portfolio management and
trading policies and procedures designed to address conflicts of interest associated with these accounts and
ensure that all clients are treated fairly over time.
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Item 7 - Types of Clients/Minimum Account Size

OCI makes its advisory services available to a wide variety of clients including, but not limited to, individuals,
pension and profit-sharing plans, trusts, estates, charitable organizations, corporations and other business
entities. The firm also serves as a sub-advisor to other investment advisors.

OCI manages accounts for employees of the firm. Most employees do not pay a fee for such services but
otherwise these employee accounts are treated like other client accounts. OCI maintains portfolio
management and trading policies and procedures designed to address conflicts of interest associated with
these accounts and ensure that all clients are treated fairly over time.

OCI and LRC have a targeted minimum account size is $1,000,000; however, this minimum may be waived
in certain circumstances.