Primm & Co Inc

Item 5 – Fees and Compensation

Our sole business is providing investment management and our fees are based on the market value of the assets
under management. We charge 1% on the first million, ¾% on the second million, .6% on the third million with
accounts over three million subject to negotiation. Fees are payable in advance and we prefer to deduct the fee from
the clients’ accounts but will allow any client to pay by check after reviewing their bill. Fees can also be negotiated
based on specific circumstances. An example would be exempting a large, low tax cost security where we have
restricted authority. We may also agree to an annual fixed fee that is mutually acceptable.

Beside our fee a client can pay other fees to the custodian including brokerage fees, fees on foreign transactions, fees
on returned checks, and, when mutual funds are used, a management fee to the mutual fund as well as a transaction
fee to the custodian for purchase or sale of the fund. This list might not be exhaustive but any and all fees are
disclosed on each client’s monthly custodial statement, the exception being mutual fund management fees paid to
t h e fund company. We do not use load funds. Item 12 contains more information on our brokerage practices.

For the clients that pay our fee in advance our contract and our policy provides for the client to receive a rebate of
the fee for the unused contractual period should they terminate the agreement during the quarter. We ask for a 2
week written notice but generally accept a verbal notice if it is definitive. We rebate the fee to the date of
termination on a pro rata basis. Pro-rated seems self-explanatory but an example is if a termination occurs on the
forty fifth day of the quarter the client will be sent one half of the quarterly fee on a timely basis which would
typically be within a week.

Item 7 Types of Clients

We provide investment advice to individuals, trust accounts, charitable foundations, and retirement plans. We do not
have minimum requirements for opening or maintaining an account. For many years we have not been soliciting or
accepting new clients unless they are related in some way to a current client where we may make an exception to
t h a t rule.