Steady Returns LLC

Item 5: Fees and Compensation

A. Fee Schedule

Investment Supervisory Services Fees

               Total Assets Under                           Annual Fee
                 Management
           All assets up to $250,000                           1.25%

            All assets over $250,000                           1.00%

These fees are negotiable depending upon the needs of the client and the size,
complexity, and nature of the portfolio managed. The final fee schedule is set forth in
the Investment Advisory Contract. Because the fees are negotiated, not all clients will
pay the same fees. SR uses the fee schedule above for accounts that are part of and not
part of the Wrap Program.

Clients that do not participate in the Wrap Program pay separate broker-dealer
custodian execution and transaction charges in addition to SR’s fee and therefore may
pay more in total fees than clients in the Wrap Program, depending on the amount of
trading activity in their account(s).

Further, a client may pay a higher or lower fee depending on considerations such as the
size of the client’s account, the amount of time the client has maintained an account
with SR, and/or the combined market value of related portfolios. While SR believes
that its fees are competitive, clients may find lower or higher fees for comparable
services from other sources.

Investment advisory fees are charged quarterly in advance as a percentage of the
client’s account value. These asset-based fees are assessed on all billable assets under
management, which include securities, cash, and money market funds, and will be
deducted from the client’s account(s).

New accounts will not be charged an advisory fee for the quarter in which they are
opened. The initial advisory fee will be determined based on the account value on the
last business day of the first partial or full quarter, or the last value provided by the
custodian. All subsequent investment advisory fees will be determined as a percentage
of the portfolio valued on the last business day of the previous quarter, or the last value
provided by the custodian.

Clients may terminate their contracts without penalty, for full refund, in the first five
days of the first quarter the account is being charged a fee. Thereafter, clients may
terminate the contract with thirty (30) days’ written notice. SR may terminate
providing investment advisory services upon written notice of termination to the
client or upon the occurrence of certain events as described in the Investment
Advisory Contract. After the termination date, SR has no responsibility to provide
ongoing investment advice to the client.

Refunds are given on a prorated basis, based on the number of days remaining in a
quarter at the point of termination. The fee refunded will be the balance of the fees
collected in advance minus the daily rate* times the number of days in the quarter up
to and including the day of termination. (*The daily rate is calculated by dividing the
quarterly investment advisory fee by the number of days in the termination quarter.)

SR may make amendments to the investment advisory fee schedule outlined in the
Investment Advisory Contract at any time with at least thirty 30-day’s written notice
to the client.

Information regarding SR’s fees and compensation related to the Wrap Program may
be found in SR’s Wrap Program Brochure, which clients may obtain by contacting their
IAR for a copy.

B. Payment of Fees

Payment of Investment Supervisory Fees

Advisory fees are withdrawn directly from the client’s accounts with client’s written
authorization. Fees are paid quarterly in advance.

C. Clients are Responsible for Third Party Fees

SR’s investment advisory fees are separate from charges assessed by third parties, such
as broker-dealers, custodians, or mutual fund companies. Clients are responsible for
the payment of all third-party fees.

A client incurs brokerage and other transaction costs charged by the broker-dealer(s)
executing the transactions and the custodians maintaining the client’s assets. These
costs include, but are not limited to, brokerage transaction and money movement costs,
commissions, ticket charges, fed fund wire fees, custodial fees, and margin interest.
These costs are in addition to SR’s investment advisory fees and are not shared with
SR.

Mutual funds charge an advisory fee in addition to the management fee a client pays
to SR. Some funds also assess administrative fees and 12b-1 fees. SR does not receive
any portion of these fees. These fees are in addition to the investment advisory fees SR
charges. The client does not pay these fees directly; rather, they are deducted from the
mutual fund’s assets and will affect the performance of the investment. These funds’
advisory, administrative, and 12b-1 fees are described in the funds’ prospectuses.
Mutual fund share prices and execution costs may differ based on share class. In certain
instances, SR will review the cost of a fund’s share classes in conjunction with execution
costs to assure that it meets its fiduciary duty to obtain best execution.

If a mutual fund has a frequent trading policy, the policy can limit a client’s transactions
in shares of the fund (e.g., rebalancing, liquidations, deposits, or tax harvesting).

If a client holds a variable annuity, there are mortality, expense, and administrative
charges, fees for additional riders on the contract, and charges for excessive transfers
within a calendar year imposed by the variable annuity sponsor. If a client holds a REIT
as part of an account, there are dealer management fees and other organizational,
offering, and pricing expenses imposed by the REIT. If a client holds a Unit Investment
Trust (‘UIT”) in the Investment Management account, UIT sponsors charge creation
and development fees or similar fees.

Further information regarding fees assessed by a product sponsor is available in the
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Item 7: Types of Clients
SR generally provides management supervisory services to the following types of clients:

           ❖ Individuals
           ❖ High-Net-Worth Individuals

Minimum Account Size

There is an account minimum of $50,000, which SR may waive based on the needs of the client
and the complexity of the situation.