Santa FE Advisors LLC

Fees and Compensation – Item 5

SFA, in providing its investment advisory services to clients, selects investments for the
client and performs the other functions specified by the client in the investment
management agreement.

Clients pay an investment management fee to SFA for the services provided under the
investment management agreement, calculated and paid monthly in arrears based on the
average fair market value of the assets in their accounts during the month. The fee
percentage, expressed as an annual rate, is displayed in the table below. Fair market value
shall be determined in good faith by SFA, and may include accrued income. In valuing
investments in limited partnerships and other collective investment vehicles, SFA may
use the most recent valuation (including estimated valuations) obtained from the
manager or administrator/recordkeeper of the investment vehicle. By signing the
investment management agreement with SFA, Clients agree to the direct debit of the
investment management fees from their client account(s). Subject to SFA approval,
clients may request to be billed for investment management fees.

In addition to SFA’s investment management fee, underlying investments such as
collective investment vehicles (mutual funds and exchange traded funds), hedge funds
and separately managed accounts carry fees and expenses that are charged by the
manager of the underlying investment and other service providers. In addition, accounts
are subject to other fees and costs, such as custodial fees, broker-dealer commissions, and
transaction charges.

       Fee Schedules

Below are SFA’s standard fee schedules.         In specific situations, fees may also be
negotiated.
            Discretionary                                  Fee

             On the first $1 million                       1.00%

             On the next $4 million                        0.75%

             On the next $5 million                        0.55%

             On amounts over $10 million                   0.35%

                               Page 5 of 12 – Form ADV Part 2A

              Non - Discretionary                          Fee

              On the first $1 million                      1.25%

              On the next $4 million                       1.00%

              On the next $5 million                       0.75%

              On amounts over $10 million                  0.50%

SFA assesses a minimum annual fee of $7,500 per relationship, irrespective of asset size.
Subject to management approval, the minimum fee may be waived.

Fees for financial planning only services are charged on an hourly basis and negotiated
based on the scope of the engagement.

Neither SFA nor any of its supervised persons accepts compensation for the sale of
securities or other investment products, including asset based sales charges or service fees
from the sale of mutual funds.

Performance Based Fees and Side-by-Side Management – Item 6

SFA does not charge any performance based fees.

Types of Clients – Item 7

SFA provides investment management and financial planning services to individuals,
high-net-worth individuals, families, trusts, institutions, charitable organizations and to
a limited extent, employer sponsored retirement plans.

SFA generally requires a minimum of $1,000,000 of assets under management for each
client relationship. Subject to management approval, the minimum assets under
management requirement may be waived.

                               Page 6 of 12 – Form ADV Part 2A

Methods of Analysis, Investment Strategies and Risk of Loss – Item 8

       Investment Process

SFA is a manager of global multi-asset class investment portfolios with a long term,
absolute return orientation. We believe that well-diversified portfolios achieve superior
investment results over time. Client portfolios are diversified across asset classes,
investment style and geographic regions. As described earlier, we do not match our
portfolios to a benchmark, in fact, our client portfolios may deviate considerably from our
neutral strategic position. These changes result from reducing risk and capturing
opportunities due to asset class mispricing.

While we analyze each investment on a stand-alone basis, we view risk at the portfolio
level and assess each investment’s risk in that context as we construct client portfolios.
Client portfolios are constructed using both passively and actively managed investment
vehicles. Mutual funds and exchange traded funds (“ETFs”) are primarily used in the
construction of client portfolios. We may also use limited partnerships and separately
managed accounts depending on a client’s investment objectives and overall portfolio
size. SFA does not provide advice for the purchase of individual securities in client
portfolios.

       Manager Evaluation and Due Diligence

SFA conducts research on every fund or separately managed account used in client
portfolios. This due diligence is performed prior to adding the fund to our approved list
and recommending the investment for use in client portfolios. Once a fund is added to
our approved list, we institute a regular monitoring process which includes telephone
calls, site visits, review of positioning, and continued performance analysis.

For actively managed investment strategies, the process begins with qualitative screening
which includes an assessment of performance and consistency criteria such as past
relative and absolute investment returns, style drift, drawdowns, volatility, and expenses.
The screens include a preliminary assessment of the management team, its strategy,
investment philosophy and process. We also consider the repeatability of the investment
approach, risk management and the operational controls utilized by the investment
manager. Prior to inclusion in the SFA approved list, investment managers are generally
interviewed either in person or via conference call. Investment vehicles such as hedge
funds and other alternative managers require additional due diligence, including a review
of their counterparties including custodian, prime broker(s), auditor, and administrator.

We primarily utilize passively managed investments, index funds, for those asset classes
or subclasses that we believe are efficient or where we believe the cost of active security
selection makes it difficult to add value. Examples of these subclasses are US large cap
equities, real estate, and high grade fixed income. Our review of the index products
includes performance, adherence to the relevant index, liquidity, assets under
management, and cost.

                               Page 7 of 12 – Form ADV Part 2A

       Client Portfolio Construction

SFA invests each client portfolio consistent with the objectives and risk tolerance of the
overall client relationship. Each client portfolio is governed by an investment policy
statement which defines risk parameters and is agreed upon with the client at the
beginning of the relationship. The investment policy statement is adjusted throughout
the client relationship as objectives and restrictions change. Institutional clients of SFA
may have proprietary investment policy statements which SFA will utilize to govern the
relationship. We will also advise institutional clients on revisions to their proprietary
investment policy statements.

Once we have determined the appropriate risk profile of the client, we will then apply an
appropriate asset allocation. The asset allocation will reflect the investment process and
manager due diligence described above. SFA maintains a limited number of risk based
portfolios that are used as guidelines for client portfolios. These portfolios are broadly
titled Aggressive Growth, Growth, Moderate, Balanced, Conservative and Capital
Preservation. This terminology is subject to change based on market conditions and
generally understood investment terminology. Client portfolios are carefully monitored
and adjusted as we alter our view based on changing market conditions.

       Investment Strategy and Research Process

SFA typically allocates clients’ assets among mutual funds, exchange traded funds,
unregistered investment funds (“hedge funds”) and separately managed accounts that are
managed by unaffiliated third-party money managers. We may offer advice about specific
investment managers who specialize in various disciplines, including, but not limited to
domestic and international equities, fixed income (including high yield, international and
investment grade), alternative strategies such as global macro and real estate, and cash
management. SFA may also recommend investments in hedge funds which invest in
venture capital, private equity, and other types of unregistered funds.

SFA does not actively trade in nor does it recommend individual equity or fixed income
securities. Clients of SFA may have long-term holdings of individual securities or other
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