Townsend Asset Management Corp

Item 5: Fees and Compensation

     A. Fee Schedule and Method

               a. Consulting, Tax Preparation and/or Financial Planning
                  Fees for services such as consulting, tax preparation and/or financial planning may be
                  determined as follows:
                       i. Hourly Rates – these rates vary depending on the staff member(s) rendering the
                          service the service and the service provided. Hourly rates normally range from
                          $250-$500.
                      ii. Flat Fee – A flat or project fee may be quoted.
                     iii. Retainer Fees – A retainer fee may be charged for services of an ongoing nature.

               b. Investment Management
                  Investment management services are normally billed based on a percentage of the
                  value of the assets being managed. Annual Investment management fees typically range
                  from 0.30% to 1.10% and this percentage may decrease as the value of the assets being
                  managed increases. Our annual fees for investment management or wealth
                  management services are prorated in the initial quarter to the account funding date.
                  Clients are generally charged quarterly, in advance, based upon a percentage (%) of the
                  market value of the assets under management as of the last business day of the
                  previous quarter, as valued by the Custodian, and generally in accordance with the fee
                  schedule below.

                                                                                 Annual Fee
                                     Value of Portfolio Assets
                                                                            (% of Portfolio Value)
                       On first $2 million                                         1.00%

                       On excess over $2 million, up to $3 million                 0.90%

                       On excess over $3 million, up to $4 million                 0.80%

                       On excess over $4 million, up to $5 million                 0.70%

                       On excess over $5 million, up to $6 million                 0.60%

                       On excess over $6 million, up to $7 million                 0.50%

                       On excess over $7 million, up to $10 million                0.40%
                       On excess over $10 million, up to $15
                                                                                   0.35%
                       million
                       On excess over $15 million, up to $20
                                                                                   0.30%
                       million
                       Over $20 million                                            Quoted

Part 2A of Form ADV: Firm Brochure               Date: 2/27/ 2026 7 of 19

                     The Fee schedule above is tiered so that Assets at each level are charged the
                     corresponding fee.

               c. Wealth Management
                  Fees for wealth management services are individually quoted for each client and are
                  influenced by the value of the assets being managed, a client’s overall assets and net
                  worth, and the complexity of their financial situation.

               d. Fee Variances
                  Townsend strives for our fees to be fair, reasonable and to fit a client’s situation,
                  circumstances, and needs. Therefore, fees may be negotiated, depending on the nature
                  of the services being provided, types of investments being used, style and frequency of
                  trading, or other factors. Your specific fee is described in the Engagement Letter that is
                  signed by both Townsend and the client.

                     Townsend considers cash to be an asset class, and include cash balances in our fee
                     calculation. There are some cases, where Townsend may not bill on a client’s cash
                     reserves, for example, where a client has designated significant percentage / amount of
                     cash to be held aside purposefully.

     B. Fee Billing

          Fees for hourly services are billed upon the completion of the service.

          Flat fees that are charged for one-time engagements are also customarily billed at the
          completion of the service, although an up-front payment of part of the fee may be required.

          Normally our fees are deducted from the client’s investment account quarterly, although
          clients can choose to be billed directly instead.

     C. Other Fees or Expenses

          In addition to fees charged by the firm, clients can also incur other additional fees or expenses.
          The custodian or brokerage firm holding client accounts can charge custodial fees. Brokerage
          fees or other transaction costs can be incurred when buying or selling securities. Townsend
          generally uses mutual funds without sales charges; however, all mutual funds have internal
          expense costs, and some charge redemption fees if a fund is sold too soon after purchase. The
          firm makes every effort to minimize these other fees or expenses. Refer to Item 12 in our
          brochure for further information on our brokerage practices.

Part 2A of Form ADV: Firm Brochure          Date: 2/27/ 2026 8 of 19

     D. Refunds of Fees

          Upon termination of any account, unearned fees will be promptly refunded. In calculating a
          client’s reimbursement of fees, we will pro rate the reimbursement according to the number of
          days remaining in the billing period.

     E. Other Compensation
...

Item 7: Types of Clients
          Our clients include individuals, high net worth individuals, trusts, partnerships, corporations, non-
          profit organizations, and retirement plans.

          Townsend does not require any minimum account size, although we may require a minimum
          fee, depending on the value of the assets being managed.