van Diest Capital LLC

Item 5: Fees and Compensation

A. Fee Schedule

Portfolio Management Fees

        Total Assets Under Management             Annual Fees
        $0 - $500,000                             1.35%

        $500,001 - $1,000,000                     1.25%

        $1,000,001 - $2,500,000                   1.00%

        $2,500,000 - $5,000,000                   0.90%

        $5,000,001 - $10,000,000                  0.80%

        $10,000,001 - $25,000,000                 0.70%

        $25,000,001 - $50,000,000                 0.40%

        $50,000,001 - $100,000,000                0.30%

        $100,000,001 - AND UP                     0.25%

Fees are paid in advance. VDC calculates fees based on the account value on the last
business day of the prior billing cycle. VDC uses a prorated feed based on the date funds
are initially received and the aggregate amount of assets under management for the
household.

If aggregate household assets are below $150,000 then VDC will charge a $1,500 financial
planning fee.

These fees are generally negotiable and the final fee schedule will be memorialized in the
client’s advisory agreement. Clients may terminate the agreement without penalty for a
full refund of VDC's fees within five business days of signing the Investment Advisory
Contract. Thereafter, the agreement may be terminated by either party by giving the other

party notice within 15 days of termination, unless VDC waives this time period on behalf
of the client. VDC will refund any unearned fees, and prorated if applicable, within 15
days of the termination date. In the event, VDC fails to refund unearned prorated fees
within the 15-day time period, VDC will pay client interest on the unreturned fees as
provided in the Investment Advisory Contract.

Financial Planning Fees

Fixed Fees

The negotiated fixed rate for creating client financial plans for individuals or high-net
worth individuals is between $1,500 and $10,000. The negotiated fixed rate for more
complex plans for charitable organizations, corporations or business entities in an
outsourced Chief Investment Officer role is up to $250,000.

Hourly Fees

The negotiated hourly fee for these services is between $150 and $5,000.

Clients may terminate the agreement without penalty, for full refund of VDC’s fees,
within five business days of signing the Financial Planning Agreement. Thereafter, clients
may terminate the Financial Planning Agreement generally upon written notice.

Retirement Planning Services

Asset-Based Fees

        Total Assets Under Management         Annual Fee
        All Assets                            1.00%

In determining the plan account's value for calculating asset-based fees, VDC will rely
upon the valuation of assets provided by the plan sponsor or the plan’s custodian or
record keeper without independent verification.

These fees are generally negotiable and the final fee schedule will be memorialized in the
client’s advisory agreement. Clients may terminate the agreement without penalty for a
full refund of VDC's fees within five business days of signing the Retirement Planning
Agreement. Thereafter, clients may terminate the Retirement Planning Agreement
generally with 15 days' written notice.

Fixed Fees

The rate for retirement planning is between $2,000 and $100,000. The final fee schedule
will be memorialized in the client’s advisory agreement. This service may be canceled
with 15 days’ notice.

B. Payment of Fees

Payment of Portfolio Management Fees

Asset-based portfolio management fees are withdrawn directly from the client's accounts
with client's written authorization on a monthly basis. Fees are paid in advance.

Payment of Financial Planning Fees

Financial planning fees are paid via check and wire.

Fixed financial planning fees are paid in arrears upon completion.

Hourly financial planning fees are paid in arrears upon completion.

Payment of Retirement Plan Fees

Retirement planning fees are withdrawn directly from the client's accounts with client's
written authorization on a monthly basis, or may be invoiced and billed directly to the
client on a monthly basis. Clients may select the method in which they are billed. Fees are
paid in arrears.

C. Client Responsibility For Third Party Fees

Clients are responsible for the payment of all third-party fees (i.e. custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
distinct from the fees and expenses charged by VDC. Please see Item 12 of this brochure
regarding broker-dealer/custodian.

D. Prepayment of Fees

VDC collects its fees in arrears. It does not collect fees in advance.

E. Outside Compensation For the Sale of Securities to Clients

James Roger Van Diest is a registered representative of a broker-dealer and an insurance
agent and in these roles, accepts compensation for the sale of investment products to VDC
clients.

1. This is a Conflict of Interest

   Supervised persons may accept compensation for the sale of investment products,
   including asset based sales charges or service fees from the sale of mutual funds to

           VDC's clients. This presents a conflict of interest and gives the supervised person an
           incentive to recommend products based on the compensation received rather than on
           the client’s needs. When recommending the sale of investment products for which the
           supervised persons receives compensation, VDC will document the conflict of interest
           in the client file and inform the client of the conflict of interest.

       2. Clients Have the Option to Purchase Recommended Products From
       Other Brokers

           Clients always have the option to purchase VDC recommended products through
           other brokers or agents that are not affiliated with VDC.

       3. Commissions are not VDC's primary source of compensation for
       advisory services
...

Item 7: Types of Clients

VDC generally provides advisory services to the following types of clients:

       ❖      Individuals
       ❖      High-Net-Worth Individuals
       ❖      Pension and Profit Sharing Plans
       ❖      Charitable Organizations
       ❖      Corporations or Business Entities

There is no account minimum for any of VDC’s services.