Opus Capital Group LLC

Item 5 – Fees and Compensation

All fees are subject to negotiation.

The specific manner in which fees are charged by Opus Capital Management is established in a
client’s written agreement with us. We generally bill our fees on a quarterly basis in arrears each
calendar quarter based on the clients’ assets under management. Clients may also elect to be
billed directly for fees or to authorize us to directly debit fees from client accounts. Management
fees are prorated for each capital contribution and withdrawal made during the applicable
calendar quarter; fees are not prorated for contributions and withdrawals that would create an
adjustment of less than $20. Accounts initiated or terminated during a calendar quarter will be
charged a prorated fee. Upon termination of any account, any earned, unpaid fees will be due
and payable.

Our advisory fees are exclusive of brokerage commissions, transaction fees, and other third-party
costs and expenses which may be incurred by the client. Clients may incur certain charges
imposed by custodians, brokers, third party investment and other third parties such as fees
charged by managers, custodial fees, deferred sales charges, odd-lot differentials, 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 our advisory fees.

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

Our fees are based on a percentage of the client’s assets under our management.

For Wealth Management accounts, our standard fee schedule is 1.00% (per annum) on all assets
managed.

Item 7 – Types of Clients

We offer investment advisory services to individuals and high net worth individuals, public and
corporate pension and profit-sharing plans, charitable institutions, foundations, endowments, and
corporations. Generally, the minimum account size is $1,000,000.

Item 8 – Analysis and Strategy

Analysis Methods

We utilize an asset allocation strategy which we implement through investments in mutual funds,
exchange-traded funds, commingled vehicles and sometimes individual securities, in separately
managed accounts.

Investment Risk

All types of investments involve some risk of loss, in some cases a greater risk of loss than others,
and all investors, including our clients, should be prepared to bear such risk.

We do not believe our methods of analysis or investment strategies involve significant or unusual
risks, other than the inherent risks of any investments.

          Lack of asset-class diversification. Certain investment allocations can be more volatile
           than diversified allocations that would include, for example, debt and fixed-income
           securities which tend to be less volatile or subject to short-term loses.
          Lack of diversification by issuer size. The shares of small- to mid-capitalization stocks,
           micro cap stocks and international stocks tend to perform differently from those of
           large-capitalization stocks under varying market circumstances, sometimes
           performing far better as a class, and sometimes not. Also, in general small- to mid-
           capitalization stocks, micro cap stocks and international stocks entail more risk than
           large-capitalization stocks due to such factors as lack of liquidity, lack of capital, lack
           of pricing power, greater vulnerability to competition, changes in exchange rates and
           geopolitical events.

While we do actively manage our accounts, with regular buying and selling of securities, we do
not engage in particularly frequent trading. We recognize that the cost of frequent trading,
particularly through increased brokerage fees, other transaction costs, and taxes can negatively
affect overall investment performance.