Parsons Capital Management Inc

Item 5 – Fees and Compensation
Investment Management Fee Schedule

       The basic fee schedule for Investment Management Services is as follows:

       1.00% per year up to $3 million
       0.80% per year for amounts over $3 million
       0.80% per year for charitable accounts

        PCM’s fees may vary and may be negotiable depending on a client’s unique situation – such
as the size of the total relationship, composition of the portfolio, anticipated future additional assets,
family holdings, related accounts, grandfathered fee schedules, courtesy accounts, low-cost basis
securities, certain passively managed investments, and pre-existing relationships with clients.
PCM may also choose to charge a lesser investment advisory fee than the basic fee, charge a flat fee
or waive its fee entirely based upon, but not limited to, the above criteria. PCM, where appropriate,
may also combine household accounts and fee on the aggregate value to benefit from threshold fee
discounts, while some accounts may be charged on an individual account basis based on their fee
schedule. This means that similar clients could pay different fees. Advisory services may also be
available from other investment advisers for similar or lower fees.

Payment of Compensation

       The client generally authorizes PCM to debit fees directly from the client’s account at the
custodian; however, if the client would like to be billed directly for fees incurred, they have that
option. Most fees are calculated based on the value of a portfolio at the close of each calendar

quarter and are charged in arrears. The portfolio values used to calculate fees may differ from the
values shown on the client’s custodial statement due to various account activities such as unsettled
trades, accrued interest and accrued dividends, which may not be reflected on that client’s custodial
statements as of the valuation date. Historically, some managers have charged their fees monthly,
and they have chosen to retain that schedule for their existing and new clients. For client accounts
that receive quarterly reports, PCM sends a copy of the invoice to the client stating the amount of
the fee, the value of the client’s assets on which the fee was based, and the specific manner in which
the fee was calculated. Clients who have their fees taken out monthly do not receive copies of
invoices.

       An account may be terminated at any time by written or oral notification. Accounts initiated
or terminated within the billing cycle will be charged a prorated fee.

Custodian Charges & Additional Fees

        As discussed in Item 12 below, when requested to recommend a custodian for a client, PCM
generally recommends Charles Schwab or Fidelity. PCM’s fees do not include certain charges
imposed by third parties (i.e. Schwab, Fidelity or other brokerage firms) which can differ depending
on the brokerage firm and may include the following: custodial fees such as wire fees and prime
broker “trade away” fees, brokerage commissions, platform fees or fees paid to sub advisors, mark-
ups or mark-downs charged for fixed income transactions, mutual fund and exchange traded fund
fees/expenses, money market management fees, 12b-1 fees and sub transfer fees, administrative
expenses, IRA and qualified retirement plan fees and other charges required by law. The type of
fees as well as the amount of these fees may differ depending on the custodian.

        When beneficial to the client, individual fixed-income and/or equity transactions may be
effected through broker-dealers with whom PCM and/or the client have entered into arrangements
for prime brokerage clearing services, including effecting certain client transactions through other
SEC registered and FINRA member broker dealers. The client generally will incur both the
transaction fee charged by the executing broker-dealer and a “trade away” fee charged by Schwab
or Fidelity.
        Mutual funds and exchange traded funds (ETFs) have varying operating expenses that are
included in the funds “expense ratio” – separate from any PCM fees. This fee information along
with any additional fee information is included in the fund’s prospectus. While there could be
occasions where clients’ own funds with higher expense ratios (i.e., legacy holdings with capital
gains consequences, minimum purchase requirements, accounts that cannot hold certain share
classes, etc.), PCM strives to select funds that have the lowest expense ratios for its clients.

       PCM does not receive any portion of these fees.

        The custodian sends a statement to the client, at least quarterly, indicating the value of and
all amounts disbursed from the account including the amount of advisory fees paid directly to PCM.
Though PCM will assist the client in establishing and maintaining accounts at the custodian, PCM
shall have no responsibility or liability with respect to custodial arrangements or the acts, omissions
or other conduct of the custodian.

Consulting Services

        PCM may provide consulting services including analysis of portfolios held outside PCM,
security analysis, financial planning or expert witness services.

        Fees for consulting services may be charged on an hourly basis (ranging from $100 to $500
per hour) or on a fixed fee basis (ranging from $1,000 to $20,000). Consulting fees are generally
paid in arrears when all work is complete.

Financial Planning

       The standard flat fee for financial planning services ranges from $3,000 to $15,000,
depending on the size of the assets and complexity of the issues involved. The hourly fee for
planning is $300.

Trusteeship

     PCM officers and employees may act as trustee(s) for trusts of clients and non-clients. If a
PCM officer or employee acts as a trustee, a trustee fee may be charged to that trust.

        PCM may be engaged to provide discretionary investment advisory services to trustee
...

Item 7 – Types of Clients
       PCM provides investment management services to individuals, qualified retirement plans,
corporate pension and profit-sharing plans, charitable institutions, endowments, trusts, estates,
foundations and corporations.