Robbins Farley LLC

Item 5:           Fees and Compensation

      A.          Fees Charged

      All investment management clients will be required to execute an Investment Management Agreement
      that will describe the type of management services to be provided and the fees, among other items. Clients
      are advised that they may pay fees that are higher or lower than fees they may pay another advisor for the
      same services and may in fact pay lower fees for comparable services from other sources. Clients are
      under no obligation at any time to engage or to continue to engage Robbins Farley for investment services.

      Asset Management

      Generally, fees vary from 0.00% to 2.00% per annum of the gross market value of a client’s assets
      managed by Robbins Farley. The fee range stated is a guide. Fees are negotiable, and may be higher or
      lower than this range, based on the nature of the account. Factors affecting fee percentages include the
      size of the account, complexity of asset structures, and other factors, such as financial planning. At no
      time will the total management fees exceed 3%.

      Fee Differentials Robbins Farley shall generally price its advisory services based upon various objective
      and subjective factors. As a result, our clients could pay diverse fees based upon the type, amount and
      market value of their assets, the anticipated complexity of the engagement, the anticipated level and scope

of the overall investment advisory and consulting services to be rendered. Additional factors effecting
pricing can include related accounts, employee accounts, competition, and negotiations.

As a result of these objective and subjective factors, similarly situated clients could pay diverse fees, and
the services to be provided by Robbins Farley to any particular client could be available from other
advisers at lower fees. All clients and prospective clients should be guided accordingly.

Financial Planning

Clients engaging the Firm for financial planning services may do so on an hourly or fixed fee basis. The
hourly rate ranges from $200 to $500 per hour. Fixed fees range from $2,000 to $10,000 per plan.
However, these fees are just guidelines, subject to change according to the complexity of the plan and the
specific client’s circumstances, because some clients have more challenging issues than others. These
complexities may not necessarily correlate with greater net worth. In the discretion of Robbins Farley,
financial planning fees received may or may not be credited towards a client’s asset management fees
incurred during the first year of the client engagement. In some cases, financial planning fees may also
be included in the asset management fee.

B.      Fee Payment

Asset Management:

For clients whose assets are managed by the firm, investment advisory fees will be debited directly from
each client’s account. The advisory fee is paid quarterly, in advance, based upon the market value of the
assets being managed by Robbins Farley on the last day of the previous billing period as valued by the
custodian of your assets, including any accrued interest. For example, if your annual fee is 1.00%, each
quarter we will multiply the value of your account on the last day of the previous billing period by 1.00%,
then divide by four (number of quarters). To the extent there is cash in your account, it will be included
in the value for the purpose of calculating fees. Once the calculation is made, we will instruct your account
custodian to deduct the fee from your account and remit it to Robbins Farley. While almost all of our
clients choose to have their fee debited from their account, we will invoice clients upon request.

For the initial quarter, the fee is calculated on a pro rata basis, meaning clients will pay a fee based on the
number of days left in the quarter in which they engage the Firm. In the event the advisory agreement is
terminated, the fee for the final billing period is prorated through the effective date of the termination and
the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate. Any
deposits or withdrawals that would result in a fee differential during the quarter of greater than or equal
to $50 will be prorated based upon the number of days remaining in the quarter in which the funds are
added or withdrawn, and the difference shall be added or subtracted from the client’s next quarterly fee.
The $50 deposit or withdrawal minimum shall not apply to the participant directed account Robbins Farley
manages (see Item 4 above for more information).

Clients whose fees are directly debited will provide written authorization to debit advisory fees from their
accounts held by a qualified custodian chosen by the client. At least each quarter, clients will receive a
statement from their account custodian showing all transactions in their account, including the fee. Fees
are calculated by Robbins Farley and not independently calculated by the custodian. Clients should
carefully review their statements, including the fee amounts, and let the Firm know of any questions.

Financial Planning: Financial planning fees will be due upon receipt of invoice from Robbins Farley or
may be billed quarterly. In many cases, clients will be asked to put forth a retainer at the onset of the
engagement which may be for up to 50% of the expected final cost.

          C.      Other Fees

      There are a number of other fees that can be associated with holding and investing in securities. In addition
      to the advisory fees paid to Robbins Farley, clients may also incur certain charges imposed by other third
      parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions. These
      additional charges may include securities brokerage commissions, transaction fees, custodial fees, margin
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Item 7:           Types of Clients

          Clients advised may include individuals, families, trusts, charitable organizations and foundations,
          pensions and corporations.