Richmond Investment Services LLC

ITEM 5 FEES AND COMPENSATION

Under a wrap fee account, the Client is charged a single, wrap fee that includes the advisory fee and either
the custodial asset-based charge or the custodial transaction-based charges, as applicable. When managing
a Client’s account in this way, RIS receives the balance of the fee after deducting any custodial asset-
based or transaction-based charges. The Firm’s financial professionals, at their discretion, can negotiate
an annual wrap fee up to a maximum of two percent (2.00%) of assets managed by RIS and may apply
the following fee schedule as provided below under “Fees and other charges”. The wrap fee is negotiated
based on various objectives and subjective factors. The complexity of the engagement as well as the level
and scope of the services to be rendered may impact the final agreed upon fee schedule. There may be
Client relationships that pre-date the association between the financial professional and RIS and, as a
result, Client wrap fees may be higher or lower than the schedule outlined below.

Fees and other charges

Individually Managed Accounts

Fees for individually managed accounts are tier priced as follows:

                Account Size                      Fee (Annual percentage) *
                $0 - $500,000                     2.00%
                $500,001 - $1,000,000             1.75%
                $1,000,001 - $5,000,000           1.50%
                $5,000,000 +                      Negotiable

Custodial account and other service fees are not covered by the annual wrap fee. These may include but
are not limited to mutual fund fees and ETF charges imposed by the fund company (e.g., management
fees, and other fund expenses, etc.), margin interest, account activity fees, and any other fee related to
maintaining a retirement account by the custodian. Additionally, for wrap accounts at LPL, the Client will
incur a ticket charge for foreign stock transactions.

All asset-based fees are deducted by the qualified custodian of record on a quarterly basis in advance, or
as otherwise indicated in the Client’s FSA. Client statements for prior deductions will be provided on a
quarterly basis.

All fees paid to RIS for investment advisory services are separate and distinct from the expenses charged
by third-party managers and investment companies to their shareholders. These fees and expenses are
described to the Client in separate disclosures. These fees will generally include third-party management
fees, an investment company management fee, other fund expenses, and in some situations a possible
distribution fee.

The Advisor will provide investment advisory services and portfolio management services, but will not
provide custodial or other administrative services. At no time will RIS accept or maintain custody of a
Client’s funds or securities except for fee deductions previously authorized by the Client. The Client may
contact the custodian directly for disbursements, account record changes, and may also do so in writing to
the custodian. The Advisor may act at the Client’s convenience to facilitate such written communications
to the custodian, provided that such action is not construed to be custody of Client assets.

The Client is responsible for all custodial and securities execution fees charged by the custodian and
executing broker-dealer. Fees paid to RIS are separate and distinct from the custodian and execution fees.

Clients may request to terminate their advisory contract with RIS, in whole or in part, by providing
advance written notice. Upon termination, any fees paid in advance will be prorated to the date of
termination and any excess will be refunded to the Client through the custodian. Client’s advisory
agreement with RIS is non-transferable without Client’s written approval.

Fee Deduction Disclosure

When the firm deducts its management fee from Client accounts utilizing a qualified custodian, the firm
is required to meet the following requirements.

a. Possess written authorization from the Client to deduct advisory fees from an account held by a
qualified custodian;

b. Send the qualified custodian a written invoice detailing the fee amount to be deducted from the Client
account; and

c. The firm must ensure that on at least a quarterly basis, the custodian sends to the Client a statement
showing all transactions within the account during the reporting period.

Defined Contribution Plan Asset Management Fees

Group self-directed, advisor discretionary, or trustee directed 401(k), 403(b), and/or other multi
participant Qualified plans (when asset-based fees are elected by a plan sponsor in connection with open-
architecture qualified plans) are billed quarterly in arrears and are tier priced as follows:

                Account Size                     Fee (Annual percentage)
                $0 - $5,000,000                  0.60%

                 $5,000,001 - $10,000,000        0.50%
                 $10,000,001+                    0.40%

Fee deductions are made from 401(k) and 403(b) by the Plan Administrator/Record Keeper on behalf of
the Plan Sponsor according to the terms of the contract for services with the advisor and paid to the
advisor by the Plan Administrator or Record Keeper.

Fees are negotiable and generally billed by RIS to the custodian, based on Client approval, and then
deducted from the Client’s plan account. In some cases, RIS may charge Clients for its services on a flat
fee basis or on a per participant basis. Furthermore, RIS may consider the number of plans advised for a
particular Client when negotiating fees. RIS and the financial professionals may have previous fee
arrangements which may deviate from the above-listed fee schedule.

Fixed Fees

To the extent specifically requested by a client, RIS may determine to provide consulting services
including financial and/or estate planning on a stand-alone fee basis per the terms and conditions of a
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ITEM 7 TYPES OF CLIENTS

RIS’s Clients generally include:
   • Individuals
   • Profit sharing plans and other qualified plans
   • Trusts, estates, or charitable organizations
   • Corporations and other business entities

RIS does not require an annual minimum fee or minimum asset level for investment advisory services.
Certain investment programs or investment products require annual minimum fees or minimum asset
levels for participation. Clients should review disclosure material or Form ADV Part 2A brochures and
consult with their financial professional about the implications of such minimum requirements before
investing in such programs or products.