St Germain Investment Management Inc

Item 5 – Fees and Compensation

St. Germain Investment Management, Inc.’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
investments and other third parties such as fees charged by managers, custodial fees,
deferred sales charges, 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. Such charges, fees and commissions are exclusive of and
in addition to St. Germain Investment Management, Inc.’s fee.

Fees

The annual fee for Investment Services will be charged as a percentage of client assets
under management, billed quarterly in arrears. The basic fee schedule per account is as
follows:

           Assets under Management [AUM]         Annual Fee
           First $250,000                        1.25%
           Next $1,750,000                       1.00%
           Next $3,000,000                       0.85%
           Amounts over $5,000,000               0.60%

Although St Germain Investment Management, Inc. has established the aforementioned fee
schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis.
Client facts, circumstances and needs are considered in determining the fee or fee schedule.
These include the complexity of the client assets to be placed under management,
anticipated future additional assets, related accounts, portfolio style, account composition,
and reporting among other factors. The specific annual fee or fee schedule is identified in
the contract between the adviser and each client, and will not exceed 1.25% except in
certain circumstances where the minimum fee is charged. A minimum quarterly
management fee of $25 applies (prorated monthly).

Some existing client fees fall outside of our basic fee schedule, based on prior negotiated
arrangements. Fees agreed upon by New England Capital with its existing clients prior to
its December 2019 merger with St Germain Investment Management Inc. will be honored,
and will not exceed 1.25%.

Generally, St. Germain Investment Management, Inc. deducts its management fee directly
from client accounts. Some clients, at the client’s request, are invoiced directly. Billing is in
arrears, on a quarterly basis, based on the average daily account balance at the close of the
billing period. In order to arrive at this daily account balance, the firm uses pricing
provided by its custodian, Charles Schwab. Charles Schwab has its own method for pricing
certain securities such as bonds. Clients are not required to pay any fees in advance. New
accounts will be charged pro rata from the date of opening. The fee for terminated
accounts will be pro rata for the time they remained with St Germain Investment
Management, Inc.

Other Fees and Separate Mutual Fund Fees

All fees paid to St. Germain Investment Management, Inc. for investment advisory services
are separate and distinct from the fees and expenses charged to their shareholders by
mutual funds, closed-end funds, or exchanged-traded funds that may be held in client
portfolios.

It is standard policy that St. Germain Investment Management, Inc. will not invest client
assets in mutual funds that have 12b-1 fees. However, if a client holds a pre-existing
mutual fund position(s) that is transferred to our management, and if it is determined to be
in the clients’ best interest to retain that positon, we make our best effort to exchange that
fund into a non-12b-1 share class if the fund company offers it, and if it is available through
the custodian. In situations where a 12b-1 fee is charged by the mutual fund company, St.
Germain Investment Management does not receive that fee.

In some cases, we have clients that originated as traditional (commission-based) brokerage
accounts that hold mutual funds with 12b-1 fees, and the client subsequently transitioned
to (fee-based) investment advisory services. If after review and agreement with the client
it is determined that no change be made to that mutual fund position, we segregate those
positions as “unsupervised assets” for billing purposes, and no management fees will be
charged against those assets. In these circumstances, St Germain Investment Management,
Inc. does not hold supervisory responsibility for those assets, and does not exercise
discretionary management.

In some cases, St. Germain Investment Management, Inc. is asked to arrange “custody” for a
client’s account in which there is little or no trading of securities, and/or no fee-based
active management of the account. In these situations, and by agreement with the client, St.
Germain Investment Management, Inc. charges a servicing fee ranging from zero to 25
basis points, depending on total client assets.

General Information on Fees

In certain circumstances, fees can be negotiable. Clients should note that similar advisory
services may (or may not) be available from other registered investment advisers for
similar or lower fees. St. Germain Investment Management, Inc. will establish fee
relationships with each client at the start of the advisory relationship.

Item 7 – Types of Clients

St. Germain Investment Management, Inc. provides portfolio management services to
individuals (other than high net worth individuals), high net worth individuals, pension
and profit sharing plans (other than plan participants), plan participants, charitable
organizations, and corporations or other businesses. Generally, St Germain Investment
Management, Inc. will open accounts with assets over $100k. The account minimum is
negotiable depending on other factors such as other assets under management, accounts
that can be linked, or potential future investment.