The Putney Financial Group LLC

Item 5         Fees and Compensation

                        INVESTMENT SUPERVISORY SERVICES ("ISS")

INDIVIDUAL PORTFOLIO MANAGEMENT FEES

The annualized fees for Investment Supervisory Services are charged as a percentage of assets under
management, according to the following schedule:

                    Assets Under Management                             Annual Fee
                          $1 - $500,000                                    2.00%
                     $500,001 - $1,000,000                                 1.35%

                    $1,000,001 - $1,500,000                              1.20%

                    $1,500,001 - $3,000,000                              1.00%
                    $3,000,001 - $5,000,000                              0.85%

                        Over $5 million                                negotiable

Fee can be calculated on either an individual or aggregate account balance as selected on the client’s
advisory agreement.

Advisory services can include discretionary or non-discretionary services for the following types of
accounts: 401K; 403b; 457; Advisory Class Variable Annuities; Unit Investment Trusts; Non-Publicly
Traded Securities; and Private Placements. These referenced assets will be aggregated with all other
securities for purposes of advisory fee calculations if the client selects to aggregate their account
balances on the advisory agreement.

Accounts are aggregated in order to achieve the lowest fee tier. For example, if an account is worth
$750,000, the quarterly fee would be $3,343.75. This is calculated as follows: the first $500,000 is
billed at 2% annually ($2,500 quarterly), then the remaining amount of $250,000 is billed at 1.35%
annually ($843.75).

Our fees are billed in arrears at the end of each calendar quarter based upon the value (market value or
fair market value in the absence of market value), of the client's account at the end of the previous
quarter. Fees will be debited from the brokerage account in accordance with the client authorization in
the Agreement of Engagement.

Negotiability of Advisory Fees: Although The Putney Financial Group LLC has established the
aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a client-by-
client basis. Client facts, circumstances and needs are considered in determining the fee schedule.
These include the complexity of the client's portfolio, assets to be placed under management,
anticipated future additional assets; related accounts; portfolio style, account composition, reports,
among other factors. The specific annual fee schedule for each client is identified in the Agreement
of Engagement, the contract executed by the adviser and each client.

Discounts, not generally available to our advisory clients, may be offered to employees and their family
members.

FINANCIAL PLANNING FEES

The Putney Financial Group LLC's financial planning fees are determined based on the nature of the
services being provided and the complexity of each client's circumstances. All fees are agreed upon
prior to entering into a contract with any client. Generally, The Putney Financial Group LLC’s financial
planning services are included in the investment advisory fee (described above). On occasion, The
Putney Financial Group LLC may charge an hourly or fixed fee for stand-alone financial planning
services at the following rates:

 Principal                                           $1,000 per hour
 Senior Advisor                                      $550 per hour

 Advisor                                                $275 per hour
 Administrative Staff                                   $125 per hour

Additionally, a $5,000 retainer is required to engage services. Any unused portion is refunded in full,
and overages are billed monthly.

GENERAL INFORMATION

Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either
party, for any reason upon receipt of 30 days written notice. Upon termination of any account, any
accrued fees will be billed up to the business day prior to the date of termination notification.

Mutual Fund Fees: The Putney Financial Group LLC does not receive any 12b-1 fees. Mutual funds
generally offer a variety of different fund share classes with different fee structures. Each share class of
a fund represents an interest in the same portfolio of securities. Some share classes charge a 12b-1 fee
from its assets for shareholder services, distribution, and marketing expenses. A lower cost share class
available that does not charge a 12b-1 fee might exist. It is usually in the client’s best interest to invest
in a lower cost share class because the returns would not be reduced by the 12b-1 fee charged by the
fund. Whenever possible, The Putney Financial Group LLC uses institutional class mutual funds to
eliminate the 12b-1 fees or will choose a share class that does not charge a fee, if one is available. If a
client holds a position in a class of a mutual fund in a Putney managed account that does pay a 12b-1
fee, that fee is automatically refunded in total to the client’s account. This process is conducted
automatically by the client account’s custodian.

All fees paid to The Putney Financial Group LLC for investment advisory services are separate and
distinct from the fees and expenses charged by mutual funds and/or exchange-traded funds (ETFs) to
their shareholders. If the mutual fund was purchased prior to working with The Putney Financial Group
LLC and previously imposed sales charges, a client may pay an initial or deferred sales charge. (If the
fund is purchased inside a The Putney Financial Group LLC advisory account, it will be delivered at net
asset value, free of any sales commission assessed by the fund.) A client could invest in a mutual fund
directly without our services. In that case, the client would not receive the services provided by our Firm
...

Item 7         Types of Clients

The Putney Financial Group LLC provides advisory services to the following types of clients:

•   Individuals (other than high net worth individuals)

•   High net worth individuals

•   Charitable trusts

Generally, a minimum of $250,000 of assets under management is required to establish a client
relationship with The Putney Financial Group LLC. This account size may be negotiable by The Putney
Financial Group LLC and The Putney Financial Group LLC may group certain related client accounts
for the purposes of achieving the minimum account size and determining the annualized fee.