The Central Trust Bank

Item 5 Fees and Compensation
Investment Advisory Services Clients who engage the Adviser for discretionary or non-discretionary
investment advisory services will pay an annual advisory fee based on a percentage of the average daily
market value and type of assets under management. The Adviser’s standard advisory fee is generally
1.00%.

Fees may be discounted based on factors such as the amount of assets to be managed, portfolio
composition, the scope and complexity of the engagement, anticipated servicing needs, related
accounts, expected future asset growth, and client negotiations. As a result, similarly situated clients
may pay different fees, and comparable services may be available from other advisers at lower fees. In
certain limited situations, the Adviser may elect to waive its fee. Account fee schedules and discounts
are reviewed annually.

The Adviser receives compensation for the platform level advisory services provided to HSA Central.
These fees are not charged to the participants.

Fee Deduction and Billing Practices Clients may authorize the custodian to deduct the Adviser’s
fees directly from their account. The Adviser’s service agreements permit the custodian to debit the
account for the advisory fee and remit payment to the Adviser in accordance with regulatory
requirements. In limited circumstances, the Adviser may allow fee invoices to be sent directly to
clients instead of debiting the account. Fee invoice payment is due upon receipt.

The Adviser generally deducts or bills advisory fees monthly, in arrears, based on the average daily market
value of the assets in the account during the prior month, or another methodology agreed upon by the
Adviser and the client. Minimum charges may apply.

Brokerage Commissions and Other Fees As described in Item 12, the Adviser generally recommends
Fidelity for brokerage and related services. Broker-dealers such as Fidelity may charge brokerage
commissions and transaction fees for certain securities transactions. Brokerage commissions and
transaction fees charged by Fidelity may be higher or lower than those charged by other broker-dealers.

In addition to the Adviser’s advisory fee and any brokerage commissions or transaction fees, clients also
incur fund level expenses associated with mutual funds and exchange traded funds.

When beneficial to the client, certain fixed income or equity transactions may be executed through
broker-dealers with whom the Adviser or the client has established prime brokerage or clearing
arrangements. In such cases, the client may incur both the transaction fee charged by the executing
broker-dealer and a “trade-away” fee charged by the custodian. The Adviser does not receive any portion
of these fees.

To help mitigate cash sweep yield dispersion, the Adviser may, typically within 30 days, purchase a higher
yielding money market fund (or other available security) on the custodian’s platform, unless the Adviser
reasonably anticipates that the cash will be used within the subsequent 30-day period to purchase
additional investments.

Fee Prorations, Minimums, and Termination The Adviser’s annual advisory fee is prorated and paid
monthly, in arrears, based on the average daily market value of the assets in the account during the prior
month. The Adviser does not generally impose a minimum annual fee or minimum asset level however, it
may, in its sole discretion, charge a lower fee based on factors such as anticipated future earning
capacity, expected future additional assets, related accounts, account composition, or negotiations with
the client.

The agreement remains in effect until terminated by either party in accordance with its terms. Upon
termination, the Adviser will debit the account for the prorated portion of the unpaid advisory fee based
on the number of days services were provided during the final billing period. Fees are not adjusted for
additions or withdrawals made during a billing period unless the advisory agreement specifies otherwise.

Item 7 Types of Clients
The Adviser’s clients are generally limited to institutional clients, including retirement plans, insurance
companies, and associations. The Adviser does not typically require a minimum annual fee or minimum
asset level for investment advisory services, although it may apply a minimum fee to certain client
accounts.

The Adviser may, in its sole discretion, charge a lower advisory fee based on factors such as anticipated
future earning capacity, expected future additional assets, the amount of assets to be managed, related
accounts, account composition, or negotiations with the client. As a result, similarly situated clients may
pay different fees. Comparable advisory services may also be available from other investment advisers
for similar or lower fees.

The Adviser provides platform level investment advisory support to HSA Central, a division of The Central
Trust Bank, relating solely to the construction and oversight of the investment menu available to Health
Savings Account (“HSA”) holders. The Adviser does not provide individualized advice, exercise
discretionary authority, or provide continuous and regular supervisory or management services to
participant accounts. Accordingly, HSA participants are not considered advisory clients for purposes of
this Brochure.