Stansberry Asset Management LLC

Item 5 - Fees and Compensation

While at times SAM may negotiate rates other than specified below, the following schedule lays out
SAM’s fees, which are charged monthly in arrears. The typical fee structure for SAM’s core offered
strategies is outlined below:

Stansberry Asset Management, LLC                                           Form ADV Part 2A

       All Strategies (Except Treasury)                            Treasury Strategy

         AUM                     Fee %                          AUM                Fee %

        First $1M           1.50% per annum                    First $1M        .50% per annum

       Next $4M             1.25% per annum                Amounts over $1M     .25% per annum

       Next $20M            1.00% per annum

   Amounts over $25M        0.75% per annum

Investment management fees are charged each month in arrears based on the average daily market
value of the assets in the client account (including net unrealized appreciation or depreciation of
investments and cash, cash equivalents and accrued interest). In limited circumstances, certain
client accounts may be grandfathered in at fee rates that are lower than those outlined above.

In addition to paying investment management fees, client accounts will also be subject to other
investment expenses such as custodial charges, brokerage fees, other transaction costs,
commissions and related costs; interest expenses; taxes, duties and other governmental charges;
transfer and registration fees or similar expenses; costs associated with foreign exchange
transactions; other portfolio expenses; and costs, expenses and fees associated with products or
services that may be necessary or incidental to such investments or accounts. Client assets may
be invested in ETFs or other registered investment companies. In these cases, the client will bear
its pro rata share of the investment management fee and other fees of the fund, which are in
addition to any fees or other compensation paid to SAM. Please refer to Item 12 of this Firm
Brochure for a discussion of SAM’s brokerage practices.

SAM may receive certain fees from private funds or other investment opportunities sponsored by
organizations that SAM has partnered with in exchange for providing services related to back office
and investor relations activities, among other general business consulting services.

Item 7 - Types of Clients

As discussed in Item 4, SAM focuses on managing separate accounts for predominantly high net
worth individuals and families.

SAM requires that a client invests a minimum of $500,000 to open an account. If the account size
falls below the minimum requirement due to market fluctuations only, a client will not be required

Stansberry Asset Management, LLC                                              Form ADV Part 2A

to invest additional funds with SAM to meet the minimum account size. SAM may waive these
minimum asset requirements in its sole discretion.