Shufro Rose & Co LLC

ITEM 5 – FEES AND COMPENSATION
Investment Advisory Fees

SRC charges an investment advisory fee to its Clients. The annual investment advisory fee is paid
quarterly in arrears and is calculated using Average Daily-adjusted Assets under Management
(“AAUM”) for the quarter—which generally includes all discretionary assets in an account that
are invested or held for investment (including cash and cash equivalents) except for those assets
that have been expressly excluded under the respective fee agreement or otherwise as determined
by the Portfolio Manager. The investment advisory fee is assessed in accordance with the fee
schedule the client authorized. SRC has, and may in the future, at its discretion, waive or reduce
the fees calculated in accordance with the fee schedule for specific accounts taking into
consideration, among other things, account strategy, current portfolio and asset classes, the size of
the account and the length of the client relationship. A detailed copy of the calculation is available
upon request.

SRC maintains the discretion to vary or modify its fee schedule subject to applicable law and
contract.

The investment advisory fee range generally offered by SRC is summarized below:

        Annual Fee (based on AAUM)
        Ranging from 0.65% to 1.50% assessed quarterly in arrears.
        529 Plans are charged a 0.50% per annum management fee.

Certain advisor groups at SRC may require a minimum account size, but reserve the right to reduce
or waive this minimum account size.

In certain circumstances, multiple accounts of Clients related by blood or marriage and/or sharing
a household may be combined to reach a certain asset under management level in order to qualify
for certain fee breakpoints. Several factors—such as the amount of assets invested, and types of
investments being made - may influence the amount of the annual fee.

Unless a Client directs otherwise, fees are deducted from the relevant account or from a related
account. For example, for some Clients, advisory fees for IRA accounts are deducted from the
Clients’ taxable accounts. When fees are deducted, the charge is shown on the monthly statement

for the month in which the charge is made. Fees are prorated for accounts that open or close during
the billing period. Existing accounts may use fee schedules or payment terms that differ from the
fee schedules or payment terms offered to new clients. If an account transfers to a different
Portfolio Manager within SRC, the fee schedule in existence immediately prior to the transfer will
govern the account unless a new arrangement is agreed upon between SRC and the relevant Client.

Clients do not pay any charges to SRC except as described above in connection with investment
advisory services. SRC does not charge commissions to Clients. SRC’s management fees may or
may not be exclusive of any fees and/or expenses charged by third-parties. Such third-party fees
and/or expenses may include, but not be limited to, custodial fees, brokerage commissions,
transaction fees, third-party investment management fees, administrative fees, odd lot differentials,
transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage
accounts and securities transactions. Some trades are assessed regulatory fees (e.g., Chicago Board
Options Exchange (“CBOE”) fees for options, and an SEC fee for all sales). If foreign securities
are purchased, additional charges for exchanging currency may be charged by the respective
custodian. With respect to investments in mutual funds including Exchange Traded Funds
(“ETFs”), management/marketing fees are charged by such funds. These fees are included in the
cost of the shares and are disclosed in the prospectuses that are sent by the custodian at the time of
purchase. In all cases, a portion of those fees (often called 12b-1 fees) are directed to the custodian.
Because SRC is not a broker-dealer, we are not allowed to receive any portion of these fees. Clients
should review their custodial statements to review all expenses.

For alternative private investment fund managers, Clients will incur management and incentive
fees, in addition to administrative, audit, legal and other such allowable expenses pursuant to the
Offering Materials. These fees and expenses will be in addition to the management fees paid to
SRC.

If SRC engages an Independent Manager to manage a portion of Client assets, SRC will generally
pay the management fees charged by such Independent Manager resulting in no increased fee to
the Client. In the event fees to an Independent Manager shall result in increased fees to the Client,
the Client shall be notified in writing and such increased fees shall become effective no earlier
than 30 days after written notice is sent to the Client, unless a written objection is sent to the
Adviser prior to the expiration of that time. Clients may also incur transaction or custodial fees on
any sub-advised accounts as Clients would if SRC were managing the assets. The Independent

Manager will send an itemized management fee calculation on a quarterly basis to SRC for review
and payment.

SRC has retained Broadridge Investor Communication Solutions, Inc. (“Broadridge”) to file
securities class actions on behalf of Clients. Broadridge bears the processing costs associated with
filing such actions and is entitled to receive fifteen percent (15%) of the gross recovery connected
to such claims. SRC receives no portion of such fee or recovered amount.

SRC has retained Globe Tax Services, Inc (“GlobeTax”) to recover over-withheld tax on
international investments on behalf of Clients. GlobeTax bears the processing costs associated
with its effort and will receive $50 or 20% - 35% whichever is greater but no more than 50% of
the amount recovered. GlobeTax is also entitled to an annual maintenance fee of $200 per account
...

ITEM 7 – TYPES OF CLIENTS
SRC's Clients are primarily individuals, high net-worth individuals, or trusts, including IRAs and
retirement accounts. The remaining accounts consist of other investment managers, charitable,

educational, endowment and corporate accounts as well as family limited partnerships or
investment clubs.