Service Academy Capital Management LLC

ITEM 5. FEES AND COMPENSATION
A.   Advisory Fees and Compensation

General Information
The IMA will determine the exact fee structure; however, fees are generally charged as a percentage of assets
based on the following schedule:

        Fee Schedule:

    •   First $1,000,000                         -       1.50%
    •   Next $4,000,000                          -       1.25%
    •   Next $5,000,000                          -       1.00%
    •   Next $15,000,000                         -       0.75%
    •   Next $75,000,000                         -       0.65%
    •   Next $150,000,000                        -       0.50%
    •   Amount over $250,000,000                 -       negotiable

The maximum fee for investment advisory services is 1.50% of the assets advised in each account. Most
advisor’s fees are billed on a pro-rata basis quarterly in arrears or in advance, based on the average daily value
of the Client’s account however some fees are billed monthly in arrears. Fees are calculated based on a 365
day year (366 days for a leap year). The fee billing schedule will be effective commencing the day that an
advisory contract is executed by the client and SACM. Fees will be calculated based on month end assets
under management each month in arrears or in advance, and the client’s account is funded unless
otherwise mutually agreed to by the client and SACM.

The only fixed fees will be the administrative fee referred to in subsection C below.

SACM may, in its discretion, either (a) debit the client’s account and cause the client’s account to pay to
SACM, any amount owing to SACM as described in the IMA or (b) bill the client for such amount, in which
case the client will pay such amount to SACM within thirty (30) days of the client’s receipt of such bill.

If fees are debited from the client’s account, SACM will send the qualified custodian an invoice or statement
of the amount of the fee to be deducted from the client’s account. In the event the account does not maintain
a sufficient cash or money market fund balance to the cover the fees, the client may deposit additional funds
(subject to any applicable restrictions for certain retirement accounts). Advisor intends to use the safeguards
provided in California Code of Regulations Section 260.237.2 paragraph (b)(3) as well as any other safeguards
provided for pursuant to the State Laws in connection with fee deductions.

Prospective clients are hereby advised that lower fees for comparable services may be available from other
sources.

Unless a client has received this Brochure at least forty-eight (48) hours prior to signing the IMA, the IMA

Service Academy Capital Management LLC
Investment Advisor Brochure (ADV Part 2A)

may be terminated by the client within five (5) business days of signing the IMA without incurring any
advisory fees.

Limited Negotiability of Advisory Fees

Fees are negotiable based on particular client circumstances.

SACM will provide advisory services to a select number of veterans, veteran families, or widows of
veterans for no fee or a substantially reduced fee.

Once SACM enters into an IMA with a client, SACM will only modify its fee as permitted under that
agreement and applicable law.

Selection of Other Advisers Fees

SACM may direct clients to third-party investment advisers. SACM will receive a flat fee on top of
the fee paid to the third party adviser. The fees shared are negotiable and will not exceed any limit
imposed by any regulatory agency. The notice of termination requirement and payment of fees for
third-party investment advisers will depend on the specific third-party adviser selected.

B.     Payment of Fees

Clients have their fees deducted from their accounts on either a monthly or quarterly basis as described
in Section A of this ITEM 5. From time to time, we reserve the right to bill clients and have them pay us
their fee directly.

Payment of Selection of Other Advisers Fees

The timing, frequency, and method of paying fees for selection of third party managers will depend on
the specific third-party adviser selected and will be disclosed to the client prior to entering into a
relationship with the third-party advisor.

C.     Other Fees and Expenses

The advisory fees do not cover, and clients pay, if applicable;
   - Commissions and other fees and charges for transactions, including execution or service charges,
       mark-ups, mark-downs spreads and odd-lot differentials
   - fees charged by an investment product and which may be described in its prospectus, offering
       memorandum or other product documents, including fund investment management fees and
       redemption fees
   - taxes relating to the account
   - other fees charged by third parties including third party custodian fees, exchange fees, electronic
       fund transfer fees, ADR fees, auction fees, charges imposed by regulatory bodies and charges
       mandated by law.
   - Fees in connection with foreign exchange transactions or conversions

Service Academy Capital Management LLC
Investment Advisor Brochure (ADV Part 2A)

Such charges, fees and commissions are exclusive of and in addition to SACM’s fee, and SACM shall not
receive any portion of these commissions, fees, and costs. Neither SACM nor any of its supervised persons
(employees) accept compensation for the sale of securities or other investment products. SACM does not
receive any indirect compensation.

ITEM 12 further describes the factors that SACM considers in selecting broker-dealers for client
transactions and determining the reasonableness of their compensation (e.g., commissions).

SACM, at its discretion, may charge an annual administrative fee (a fixed fee) of $1000 per account every
year. This fee will cover wires, administrative costs and other general expenses as determined by SACM.

ITEM 7 TYPES OF CLIENTS
Except as it relates to veterans and widows/widowers of veterans, SACM typically provides investment
advisory services to high net worth individuals, pension and profit sharing plans (covered under ERISA),
trusts, estates or charitable organizations, corporations or other business entities.