Socha Financial Group LLC

ITEM 5 - FEES AND COMPENSATION

Fees for Portfolio Management Services

The annual investment advisory fee is generally up to 1.25% of the market value of the
assets that the Firm has been instructed to manage. This fee is paid quarterly, in
advance, based on the beginning value of the assets on the first day of the quarter. For
purposes of calculating our fee, the quarter begins the month in which funds are received
into the account. The Firm does not have a minimum investment size or fee. The
investment management fee can be negotiated based on criteria such as the size of the
account, future additional assets, related accounts and account composition. These are
the reasons for a non-level fee arrangement as it relates to the DOL rules for advisory
fees.
The details of the Firm’s Fee Structure are as follows:

The Adviser’s annual fee (the “Adviser Compensation”) provided under this Agreement
shall be as follows:

          1. Accounts less than $250,000. Adviser Compensation is 1.25% of the total
market value of the Assets under management for investment management services only.
Financial planning services remain available on a separate fee basis either project or
hourly based.

         2. Accounts valued between $250,000 and $800,000. Adviser Compensation
is 1.25% of the total market value of the Assets under management and includes
investment management, tax preparation services and financial planning services.

          3. Accounts valued between $800,000 and $1.5 million. Adviser Compensation
is 1.25% of the total market value of the Assets under management on the first $800,000
dropping to 1.0% for the amount greater than $800,000 and includes investment
management, tax preparation services and financial planning services.

          4. Accounts valued over $1.5 million. Adviser Compensation is 1.25% of the
total market value of the Assets under management on the first $800,000, dropping to 1%
for the amount greater than $800,000 up to $1.5 million, dropping to .9% for the amount
greater than $1.5 million. This includes investment management, tax preparation services
and financial planning services.

Please Note: The Firm, in its sole discretion, may charge a lesser investment advisory
fee and/or charge a flat fee, or include or exclude certain services, based upon certain

criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar
amount of assets to be managed, related accounts, account composition, complexity,
competition, negotiations with client, etc.). In addition, certain clients may be subject to
prior grandfathered fee arrangements. Please Note: As result of the above, similarly
situated clients could pay different fees. In addition, similar advisory services may be
available from other investment advisers for similar or lower fees. ANY QUESTIONS: The
Firm’s Chief Compliance Officer, Michelle Socha Vang, remains available to
address any questions that a client or prospective client may have regarding
advisory fees.

The fees described above cover fees only for services that we provide. The fees do not
cover any other fees which may be incurred in connection with the implementation of a
client’s investment program, including, but not limited to, the following: (1) the fees and
costs associated with the purchase of investment products such as mutual funds; (2)
transaction costs associated with the purchase of exchange-traded funds (ETFs),
exchange-traded notes (ETNs) and individual stocks and bonds; and (3) custody costs.

If a client leaves the management program prior to the end of the quarter of their billing
cycle, a prorated portion of the management fee is returned to the client. This value is
calculated by summing the numbers of days from portfolio inception to the first billing plus
the number of days the portfolio was managed in the last quarter. This value is subtracted
from the number of days in a quarter (91.25), then divided by the number of days in the
quarter and then multiplied by the previous quarterly fee. A check is then sent to the
client for this amount with documentation of the calculation.

The fee arrangement is disclosed in advance in the Investment Advisory Agreement and
reflects the assets that are being managed, the timing of the fee and the process for
withdrawing the fee from the account. Clients may choose to pay the fee separately
rather than having it withdrawn from their account.

Share Class Selection Policy

If applicable, the Firm’s policy is to strive to purchase the most appropriate share class of
a security for client accounts. The custodian the client uses may offer multiple share
classes of certain securities, often including both no-transaction fee (NTF) and transaction
fee share classes. NTF share classes are available without a transaction fee, but typically
have a higher internal expense ratio. Transaction fee share classes generally have lower
internal expense ratios but require that the client pay a fee in connection with the
transaction. Certain share classes have minimum investment amounts.

In practice, the Firm will first narrow the universe of securities based on quantitative and
qualitative analysis and determine which securities to purchase in a client’s account. After
selecting a security, the Firm will review the available share classes and seek to

determine the share class that it believes is most appropriate based upon evaluation of
various factors, which should include at a minimum:

      Expense ratios of available share classes
      Transaction fees or redemption fees
      The intended purchase amount and investment minimums
      Available waivers of investment minimums
      Intended holding period and liquidity constraints
      Number of accounts for which the purchase will be made
      Frequency of transactions

Transaction fee funds may be beneficial when there is minimal trading in a position or
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ITEM 7 - TYPES OF CLIENTS

Our clients currently consist of individuals, high net worth individuals, charitable
organizations and small businesses. We do not require a minimum account size or a
minimum annual fee to manage these assets.