Squire Investment Management Company LLC

Item 5 – Fees and Compensation

SimCo has contracted with Focus Partners Advisor Solutions for services including trade
processing, collection of management fees, record maintenance, report preparation,
marketing assistance, and research. As a service provider assisting with trade processing,

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trade errors in client accounts may be caused by Focus Partners Advisor Solutions.
According to Focus Partners Advisor Solutions’ policies, our clients will be made whole by
Focus Partners Advisor Solutions in the event of any losses caused by Focus Partners
Advisor Solutions. Focus Partners Advisor Solutions, however, will keep gains that it causes
as a result of trade errors in client accounts. SimCo has also contracted with Focus Partners
Advisor Solutions for sub-advisory services with respect to clients’ accounts. SimCo pays a
fee for Focus Partners Advisor Solutions services based on management fees paid to SimCo
on accounts that use Focus Partners Advisor Solutions. The fee paid by SimCo to Focus
Partners Advisor Solutions consists of a portion of the fee paid by clients to SimCo and
varies based on the total client assets administered and/or sub-advised by Focus Partners
Advisor Solutions through SimCo. These fees are not separately charged to advisory clients.
The fee charged by SimCo to its clients includes all sub-advisory fees charged by Focus
Partners Advisor Solutions.

The specific manner in which fees are charged by SimCo is established in a client’s written
agreement with SimCo. For investment management and employee benefit plan services,
clients will be charged in advance at the beginning of each calendar quarter based upon the
value (market value based on independent third party sources or fair market value in the
absence of market value; client account balances on which SimCo calculates fees may vary
from account custodial statements based on independent valuations and other accounting
variances, including mechanisms for including accrued interest in account statements) of
the client’s account at the end of the previous quarter. Fees are assessed on the total
balance of managed assets, which includes securities as well as cash and cash equivalents.
New accounts are charged a prorated fee for the remainder of the quarter in which the
account is incepted (date of first trade).

For investment management and employee benefit plan services, SimCo will request
authority from the client to receive quarterly payments directly from the client's account
held by an independent custodian. Clients may provide written limited authorization to
SimCo or its designated service provider, Focus Partners Advisor Solutions, to withdraw
fees from the account. Clients will receive custodial statements showing the advisory fees
debited from their account(s). Certain third-party administrators will calculate and debit
SimCo’s fee and remit such fee to SimCo.

A client agreement may be canceled at any time, by either party, for any reason upon
receipt of 30 days written notice. Upon termination of any account, any prepaid, unearned
fees will be promptly refunded.

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SimCo’s fees are exclusive of brokerage commissions, transaction fees, and other related
costs and expenses which shall be incurred by the client. Clients may incur certain charges
imposed by custodians, brokers, third party investment and other third parties such as fees
charged by managers, custodial fees, odd-lot differentials, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions. Mutual funds and exchange traded funds also charge internal management
fees, which are disclosed in a fund’s prospectus. These fees will generally include a
management fee and other fund expenses. All fees paid to SimCo for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds and
ETFs to their shareholders.

Such charges, fees and commissions are exclusive of and in addition to SimCo’s fee, and
SimCo shall not receive any portion of these commissions, fees, and costs.

Advisory Fees

Investment Management Services:

The annual fee for investment management services will be charged as a percentage of
assets under management, according to the schedules below:

                   Asset-Based Fee Schedule for all Service Programs

                 Market Value of Assets              Annual Fee (Billed
                                                        Quarterly)

                   On the first $500,000                   1.25%

                   On the next $500,000                    0.90%

                  On the next $4,000,000                   0.70%

                  On the next $5,000,000                   0.50%

                    Above $10,000,000                      0.40%

SimCo’s minimum annual fee is $3000 which is billed at $750 per quarter. For clients with
more than $240,000 in Assets Under Management, the regular asset-based fee will exceed

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this minimum, and in that case, you’ll simply pay according to the standard tiered schedule
shown above.

As an example, a client who has a total portfolio of $2,000,000 managed by our firm would
be assessed an annualized fee of 1.25% for the first $500,000, 0.90% for the next $500,000,
and 0.70% on the next $1,000,000, for a blended rate of 0.89% on the $2,000,000 portfolio.

Fees are negotiable under certain circumstances such as on family relations or individual
circumstances including account size, potential future account growth, business
relationships and the level and scope of the services requested. Individual accounts for
...

Item 7 – Types of Clients

SimCo provides services to individuals, qualified retirement plans, trusts, charitable
organizations, corporations and small businesses.

SimCo generally requires a minimum household size of $250,000 for investment
management services. A separate minimum of $500,000 is generally required for
management services of portfolios of individual fixed income securities. SimCo maintains
the discretion to reduce or waive these minimums based upon individual client
circumstances (e.g., the nature of current investments, future contributions by client to the
account, etc.). All accounts for members of the client's family (husband, wife and dependent
children) or related businesses may be assessed fees based on the total balance of all
accounts.

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