Steele Capital Management Inc

Item 5 – Fees and Compensation

Prior to engaging SCM to provide investment advisory services, the client is required to enter into one or
more written agreements with SCM setting forth the terms and conditions under which SCM renders its
services (collectively the “Agreement”).

Individual Advisory Services. SCM provides investment management services for an annual fee based
upon a percentage of the market value of the assets being managed by SCM. SCM’s annual fee is
negotiated as a percentage of assets under management, not to exceed an annualized fee of 1.5%.
SCM, in its sole discretion, may decrease its annual minimum fee and/or charge a lesser management
fee. SCM’s annual fee is exclusive of, and in addition to, brokerage commissions, transaction fees, and
other related costs and expenses which are incurred by the client. SCM does not, however, receive any
portion of these commissions, fees, and costs. Item 12 further describes the factors that SCM considers
in recommending broker-dealers for client transactions and determining the reasonableness of their
compensation (e.g., commissions).

SCM’s annual fee is prorated and charged quarterly, in advance, based upon the market value of the
assets being managed by SCM on the last day of the previous quarter. SCM deducts the fee from the
client’s account unless the client specifically requests the fee to be directly billed. If investment
management services are terminated, unearned fees paid in advance will be prorated and refunded.
The refund is calculated based on the number of days remaining in the quarter as a percentage of the
number of total days in the quarter times the fee charged. Clients may terminate the Advisory
relationship during the first 5 days at no cost.

Retirement Plan Consulting Services. Fees for investment advice are typically charged as an annual asset
based fee, unless otherwise agreed, and are billed quarterly and in advance. Fees for services may be
charged in the form of a flat fee, hourly fee, or asset-based fee. Service fees are, likewise, negotiable,
and may take the following forms:

        •    A flat fee for selected services will generally be client specific and based on factors such as:
             (1) amount of Plan assets, (2) number of investment options, (3) number of participants, (4)
             number of client locations, (5) use of asset allocation strategies, and (6) extent of travel.
             Flat fees are typically subject to a minimum rate of $20,000.
        •    An hourly fee for selected services will generally correlate with the specific employee
             resources utilized and will range from $100 to $450 per hour.
        •    An asset-based fee for selected services is reflected in the following schedule.

The Fees Schedule for advisory services follows and reflects annual rates as a percentage of plan assets.
SCM’s annual fee is negotiated as a percentage of assets under management, not to exceed an
annualized fee of 1.25%. SCM, in its sole discretion, may decrease its annual minimum fee and/or
charge a lesser management fee.

Item 7 – Types of Clients

SCM offers portfolio management services to individuals, high net worth individuals,
corporations/businesses, corporate pension and profit-sharing plans, Taft-Hartley plans, charitable
institutions, foundations, and endowments.