Toews Corporation

Item 5 – Fees and Compensation
                                   TOEWS SPONSORED ADVISORY PROGRAMS
i-Vest Program Fees
The annual fees for i-Vest model portfolio management services are based upon a percentage of assets under
management and generally range from 0.50% to 2.00%.
                                                 i-Vest Fee Schedule
                Advisor Fee                      Client Advisor’s Fee                 Total Program Fee
                  0.50%                            0.06% - 1.50%                       0.56% - 2.00%
                                         Maximum Total Program Fee = 2.00%

Toews will receive a fee equal to 50 basis points (0.50%) of the value of the account, payable quarterly in advance
on the first day of each quarter. The total fee the client will pay will be a combination of Toews's 50 basis points
and the fee that the Financial Intermediary charges for its services with respect to the account. The Financial
Intermediary usually charges between 6 basis points (0.06%) and 150 basis points (1.50%) based on the value of
the account and the client should inquire directly with the Financial Intermediary for the exact fees charged by
the Financial Intermediary. Toews will retain the first 50 basis points (prorated) of the quarterly fee, and the rest
will be paid to the Financial Intermediary, to be shared with the Client Advisor in such proportions as they shall
agree. Each Financial Intermediary has the ability to waive its fee. Toews does not have the ability to determine
or influence the amount of the fee charged by the Financial Intermediary.
Procedures to determine Toews fee: Toews’ fee is determined based on the percentage of assets invested in the
Toews Funds. Clients should understand that Toews has a financial incentive to allocate client assets to
investments in the Toews Funds rather than unaffiliated funds because the compensation received from the
underlying management fees paid by the Toews Funds is generally higher than the advisory fee Toews charges
in connection with the i-Vest program. However, as discussed above, Toews’ Funds are designed to allow Toews
to implement its investment strategy in an efficient manner. Toews will only allocate assets to unaffiliated funds
in limited circumstances where a Toews Fund is not otherwise available. In addition to disclosing these financial
incentives and related conflicts of interest, Toews has structured its compensation so that it will not receive an
adviser fee with respect to the portion of client assets invested in Toews Funds.

In instances where the Toews Funds are used in the allocation of the client's account, Toews will waive 100% of
its adviser fee if the allocation to the Toews Funds is greater than or equal to 30%. If the allocation to the Toews
Funds is less than 30%, Toews may, in its discretion, apply Toews Fee to that portion of the client's assets that
are not allocated to Toews Fund strategies. For example, if Client is only invested 10% to the Toews Funds, Toews
may charge its fee only as to 90% of the assets under management.

Initial Minimum Account Size: There is an initial suggested minimum account size of $25,000 for each strategy.
Therefore, an i-Vest program client wishing to invest in two different strategies is required to make an initial
deposit or to maintain a minimum account of $50,000. This account size is negotiable under certain
circumstances.
Investment Risk Management Services (IRMS) Program Fees
Except as otherwise provided in the advisory agreement or if a Financial Intermediary refers a client to IRMS, the
annual program advisory fee for accounts participating in the IRMS Program will be calculated as a percentage
of the value of the client's account, according to the schedule below:

                       Fee Schedule A for IRMS Accounts – Accounts Less Than $100,000

    Management Fee:                              2.30%                    Consultant’s Portion:              1.00%
  Minimum Investment:                           $50,000                  Minimum Annual Fee:                 $1,150

                  Fee Schedule B for IRMS Accounts – Accounts from $100,000 to $1,999,999

                          Assets                                            Fee                            Consultant’s
                                                                                                             Portion
                For the first $250,000 ($0 to $250,000)                    2.00%                              1.00%
            For the next $250,000 ($250,001 to $500,000)                   1.75%                              .875%
           For the next $500,000 ($500,001 to $1,000,000)                  1.50%                              .750%
          For the next $1,000,000 ($1,000,001 to $1,999,999)               1.25%                              .625%

  Minimum Investment:                      $100,000                 Minimum Annual Fee:                       $2,000

                      Fee Schedule C for IRMS Accounts – Accounts $2,000,000 and OVER

                                                                                                          Consultant’s
                          Assets                                            Fee
                                                                                                            Portion
                 For $2,000,000 and over                                   1.00%                             0.50%

                   All Negotiated Fees                                    50% of Total Management Fee

  Minimum Investment:                    $2,000,000                 Minimum Annual Fee:                 $20,000

For Accounts Greater Than $2,000,000.

An annual fee of 1% will be charged on the entire value of these accounts. A minimum annual fee of $20,000 is
required.
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Item 7 – Types of Clients
Toews Asset Management may provide advisory services to the following types of clients:
    •   Individuals (other than high net worth individuals)
    •   High net worth individuals
    •   Investment companies (including mutual funds and ETFs)
    •   Retirement plans, pension and profit-sharing plans (other than plan participants)
    •   Charitable Organizations
    •   Corporations or other businesses not listed above
    •   State or municipal government entities
    •   Registered investment advisers and broker-dealers, usually in their capacity as sponsors of wrap
        programs
    •   Investment professionals, through BII