Thielen Capital Corporation

Item 5 Fees and Compensation
Portfolio Management Services
Our fee for portfolio management services is based on a percentage of your assets we manage and is
set forth in the following blended fee schedule:

Assets Under Management             Annualized Fee**
First $1,000,000                    1.00%
Over $1,000,000                     0.70%

* Our minimum account size is $500,000 and may be waived at our sole discretion.
** We may negotiate a fixed, flat percentage of assets under management fee, or we may negotiate a
fixed, flat fee.

Our annual portfolio management fee is billed and payable quarterly in advance based on the value of
your account on the last day of the previous quarter.

If the portfolio management agreement is executed at any time other than the first day of a calendar
quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in
proportion to the number of days in the quarter for which you are a client. Our advisory fee is
negotiable, depending on individual client circumstances.

At our discretion, we may combine the account values of family members living in the same household
to determine the applicable advisory fee. For example, we may combine account values for you and
your minor children, joint accounts with your spouse, and other types of related accounts. Combining
account values may increase the asset total, which may result in your paying a reduced advisory fee
based on the available breakpoints in our fee schedule stated above.

We will deduct our fee directly from your account through the qualified custodian holding your funds
and securities. We will deduct our advisory fee only when the following requirements are met:

    • You provide our firm with written authorization permitting the fees to be paid directly from your
      account held by the qualified custodian.
    • We send you a fee statement showing the amount of the fee, the value of the assets on which
      the fee is based, and the specific manner in which the fee was calculated.
    • The qualified custodian agrees to send you a statement, at least quarterly, indicating all
      amounts dispersed from your account including the amount of the advisory fee paid directly to
      our firm.

We encourage you to reconcile our fee statements with the statement(s) you receive from the qualified
custodian. If you find any inconsistent information between our fee statement and the statement(s) you
receive from the qualified custodian, please call our main office number located on the cover page of
this brochure.

You may terminate the portfolio management agreement upon 30-days' written notice to our firm. You
will incur a pro rata charge for services rendered prior to the termination of the portfolio management
agreement, which means you will incur advisory fees only in proportion to the number of days in the
quarter for which you are a client. If you have pre-paid advisory fees that we have not yet earned, you
will receive a prorated refund of those fees.

Retirement Plan Consulting
Our advisory fees for these customized services will be negotiated with the Plan sponsor or named
fiduciary on a case-by-case basis. We charge up to 0.50% based upon total Plan assets for our
retirement plan consulting services. Our fees are negotiable and payable monthly or quarterly in
arrears and/or in advance depending on the vendor or record keeper.

You may terminate the retirement plan consulting services by providing written notice to our firm. The
retirement plan consulting fee will be prorated for the quarter in which the termination notice is given.

Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in
mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds or exchange
traded funds (described in each fund's prospectus) to their shareholders. These fees will generally
include a management fee and other fund expenses. You will also incur transaction charges and/or
brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by

the broker-dealer or custodian through whom your account transactions are executed. We do not
share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or
custodian. To fully understand the total cost you will incur, you should review all the fees charged by
mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices,
please refer to the Brokerage Practices section of this brochure.

Compensation for Sales of Securities
We do not buy or sell securities to earn commissions and do not receive any compensation for
securities transactions, including asset-based sales charges or service fees from the sale of mutual
funds, in any client account, other than the investment advisory fees noted above.

Pursuant to California Code of Regulations Section 260.238(j) we hereby disclose that lower fees for
comparable services may be available from other sources.

IRA Rollover Considerations
As part of our investment advisory services to you, we may recommend that you withdraw the assets
from your employer's retirement plan and roll the assets over to an individual retirement account
("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our
management, we will charge you an asset based fee as set forth in the agreement you executed with
our firm. This practice presents a conflict of interest because persons providing investment advice on
our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based
compensation rather than solely based on your needs. You are under no obligation, contractually or
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Item 7 Types of Clients
We offer investment advisory services to individuals, business development companies, pension and
profit sharing plans, charitable organizations, and corporations.

In general, we require a minimum of $500,000 to open and maintain an advisory account. At our
discretion, we may waive this minimum account size. For example, we may waive the minimum if you
appear to have significant potential for increasing your assets under our management. We may also
combine account values for you and your minor children, joint accounts with your spouse, and other
types of related accounts to meet the stated minimum.