St Johns Investment Management Company LLC

Item 5.        Fees and Compensation

Portfolio Management Fees

Our fees for Portfolio Management Services for discretionary and non-discretionary accounts are based
upon a percentage of assets under our management, in accordance with the following fee schedule:

Assets Under Management ($)            Annual Fee (%)

First $1 million                               1.00%
                      St. Johns Investment Management Company, LLC |Form ADV Part 2A                4

Next $4 million                               0.70%
Over $5 million                               0.50%

The market value of each client account is determined by the firm, in accordance with the valuation
methodology used in the client’s quarterly statement provided by the custodian.

Portfolio management fees are charged quarterly in advance, based upon the net value of the assets in
the client account on the last business day of the previous quarter.

Portfolio Management Services may also be provided based upon a negotiated fixed fee, charged
quarterly in advance or in arrears, as agreed with each client.

Fees in General:

Depending on the particular arrangement with each client, we will either invoice clients or directly
debit their custodial accounts for portfolio management fees.

Fees for all services are negotiable based upon certain criteria (i.e. level of service required,
anticipated future additional assets, dollar amount of assets to be managed, related accounts, account
composition and complexity, negotiations with client, etc.).

We, from time to time, may and do group certain related client accounts for the purposes of determining
the account size and/or annualized fee.

Certain client agreements may be governed by fee schedules different from those listed above.

Unless agreed otherwise, any and all account asset classes, including cash positions, are included in the
firm’s advisory fee calculation. At certain times our advisory fee may exceed the money market yield for
cash assets.

Account Termination and Refunds:

Advisory agreements may be terminated by either party. Clients may terminate the advisory
agreement by providing us with notice at our principal place of business. If you notify your
account’s custodian that you’re terminating the custodial account linked to your separately managed
account with our firm, we will consider this to constitute a notice of termination.

Upon termination of an account, any prepaid, unearned fees will be promptly refunded on a pro-
rated basis, and any earned, unpaid fees will be due and payable on a pro-rated basis, unless
waived at adviser’s sole discretion.

We will have no obligation to recommend or take any actions with regard to the securities, cash or
other investments in a terminated account, but we may, at our discretion, assist you in liquidating
assets and in effecting the transfer of assets to a new custodian designated by you.

                     St. Johns Investment Management Company, LLC |Form ADV Part 2A               5

Mutual Fund and ETF Fees and Expenses: All fees paid to our firm for investment advisory services
are separate and distinct from the fees and expenses charged by mutual funds and ETFs to their
shareholders. These fees and expenses are described in each fund's prospectus. These fees will
generally include a management fee, other fund expenses, and a possible distribution fee. A client
could invest in a mutual fund or an ETF directly, without the services of our firm. In that case, the
client would not receive the services provided by us which are designed, among other things, to
assist the client in determining which mutual fund or funds or ETFs are most appropriate to each
client's financial condition and objectives. Accordingly, the client should review both the fees
charged by the funds and ETFs and the fees charged by us to fully understand the total amount of
fees to be paid by the client and to thereby evaluate the advisory services being provided.

Brokerage, Custodial and Other Transaction Fees

In addition to advisory fees paid to our firm, clients will also be responsible for all transaction,
brokerage, trade-away and custodial fees incurred as part of their account management. Please see

Item 7.        Types of Clients

Our firm primarily provides advisory services to the following types of clients;
   • Individuals, including high net worth individuals
   • Trusts, estates and charitable organizations
   • Corporations or other business entities
   • Pension and profit sharing plans
   • Charitable organizations

We do not require a minimum fee for any client account.