Occam Capital Management LLC

ITEM 5 – FEES AND COMPENSATION
ADVISORY FEES AND BILLING PROCEDURES
Investment Management Services
Advisory fees for investment management services are due and payable quarterly in advance (i.e., at the
beginning of each calendar quarter). We transmit our advisory fee calculations to the account custodian
electronically after the beginning of each calendar quarter. Advisory fees are calculated as a percentage
of assets under management (See Investment Advisory Fee Schedules below) and based on the value of
the account(s) as listed on a national securities exchange or the principal market where the securities
are traded, at the closing price, as of the last business day of the calendar quarter. Additionally, billing
valuations for fixed income securities often include accrued interest and equity dividend accruals. Also,
margin interest, if applicable, accrues monthly.

                                 INVESTMENT ADVISORY FEE SCHEDULES
                         Annual Fee Schedule for Equity and Balanced Accounts
                                     1.00% of the first $1,000,000
                                     .75% in excess of $1,000,000
                             Annual Fee Schedule for Fixed Income Accounts
                                        .60% of first $1,000,000
                                      .50% in excess of $1,000,000

Occam Capital’s investment advisory fee schedule is negotiable. Occam Capital® reserves the right,
under certain circumstances, to waive advisory fees.

When a client signs the investment management agreement, Occam Capital® typically receives
authorization to debit advisory fees directly from client accounts; however, clients can elect to be billed
directly.   Advisory accounts initiated during a calendar quarter will be charged a prorated fee.
Nonetheless, we do not prorate advisory fees for capital contributions and withdrawals made during a
calendar quarter.

Investment Consulting Services
Our advisory fees for investment consulting services are charged at hourly rates. We charge $200 per
hour for research and advice by principals and $75 per hour for administrative tasks by assistants. Clients
can specify a maximum advisory fee for consultation services. Payment is due upon completion of the
agreed-upon services.

Other Fees and Expenses
Advisory fees paid to our firm are separate from the third-party fees detailed below. The advisory fees
described above only cover our advisory services. Our advisory fees do not cover the other fees and/or
costs incurred by the client in connection with the implementation of investment management services.
The other fees and expenses imposed by account custodians, mutual fund companies, etc., include but
are not limited to custodial fees, American Depository Receipts (ADR) management fees, odd-lot
differentials, transfer taxes, wire transfer, electronic fund fees, and other fees and taxes on advisory
accounts and securities transactions.
Additional expenses are incurred when client assets are invested in mutual funds, exchange-traded
funds, money market mutual funds, closed-end funds, and other investment company securities. These
are direct internal expenses of the investment company that issues the security, but clients pay these
fees indirectly on an ongoing basis. The specific fees and expenses are outlined in the prospectus for
each mutual fund company. Clients are encouraged to read each mutual fund and/or ETF prospectus,
which provides detailed information about such expenses. We do not receive compensation from
mutual fund companies or their affiliates under circumstances where mutual funds or ETFs are
purchased for client accounts.

Please also review Item 12, Brokerage Practices, for information regarding the factors that Occam
Capital® considers when selecting and recommending the qualified account custodian that provides
custody and safekeeping services for our clients’ accounts.

Refund and Termination Policy
Clients may terminate an agreement for investment management services at any time by providing us
with thirty (30) days’ advance written notice. In the event we decide to terminate a client’s agreement,
we will use the same provisions (i.e., thirty (30) days’ advance written notice).
Upon receiving a client’s request to terminate investment management services, we assess advisory fees
pro rata, if applicable, to the date of termination. Any unearned portion of prepaid advisory fees will be
refunded to the client within five (5) business days of the date of termination.
We will also collect any earned but unpaid fees due prior to the disbursement of refunds. If we are
unable to deduct final fees from a client’s account(s), such as in the case of an account transfer, we will
transmit an invoice to the client, which is due upon receipt. Clients pay final invoices by mailing a check
to our address on the cover page of this Brochure.

ITEM 7 – TYPES OF CLIENTS

Occam Capital® provides investment management and investment consulting services to individuals,
high net worth individuals, pensions, profit-sharing plans, trusts, and estates. Occam Capital® prefers a
portfolio minimum of $200,000 for new client engagements. Nonetheless, we reserve the right to waive
or reduce the minimum account value based on other criteria that we deem pertinent (e.g., preexisting
relationships, related accounts, the anticipation of additional assets, etc.). Therefore, there are clients
of the firm whose account values are less than the stated minimum.