Varium Investment Partners LLC

Item 5 Fees and Compensation
Varium Investment Partners’ advisory fees are calculated as an annual percentage of assets based on
the value of the account at the time of billing and are set out in the agreement between you and the firm.
Varium Investment Partners reserves the right to negotiate fees and we may manage certain accounts
without an advisory fee, such as accounts of employees, former employees, employees’ affiliates’ or
their relations. You may pay more or less than other clients depending on certain factors, such as if you
have another account with us or if we negotiate different fees with you.

Dual Contract Program

In dual contract programs, Varium Investment Partners is paid the advisory fee shown below, which
does not include the fees for brokerage commissions, consulting services or custodial charges. For dual
contract programs, generally, the custodian will deduct the VIP advisory fee and remit such fees to
Varium Investment Partners. Where applicable, the custodian typically will deduct the VIP advisory
fee, quarterly in advance, from the account or other custodial account, in accordance with your
directions to the custodian. Varium Investment Partners’ advisory fees are calculated as an annual
percentage of assets based on the value of the account at the time of billing. The standard fee for the

VIP product available through Dual Contract Programs is listed below:

        Account                         Annual Fee
        Assets                          Percentage
         Under $500,000                 1.25%
         $500,001 - $2,000,000          1.00%
         $2,000,001 - $5,000,000        0.75%
         Over $5,000,000                0.65%

Varium Investment Partners’ minimum annual advisory fee for a dual contract program account is
$500. The VIP advisory fee for dual contract programs may be negotiated and a lower fee rate may be
offered, at Varium Investment Partners’ sole discretion.

Non-Discretionary Services

Our fees for non-discretionary management services are negotiated based on level of services provided
and size of relationship.

Other Fees and Expenses

In addition to the aforementioned, there may be other costs assessed which are not included in the fees
described above, such as fees, expenses and charges levied by mutual funds, ETFs, money market
mutual funds, costs associated with the purchase and sale of certain mutual funds and other similar
securities held in your account, dealer mark-ups, odd lot differentials, exchange or auction fees, transfer
taxes, any fees imposed by the SEC, electronic fund and wire transfer fees, clearing and custody costs,
fees or commissions for securities transactions, costs associated with temporary investment of your
funds in a cash management account, trust service charges and other charges mandated by law. Further,
interest will normally be charged on a debit balance in your account.

The fees described above do not include transaction charges for execution other than at your custodian.
Please refer to Item 12 for more information about Varium Investment Partners’ brokerage practices.

The advisory fees described above do not include fees or expenses which may be associated with the
underlying investment vehicles (such as, redemption fees, 12b-1 fees or other fund expenses) or other
regulatory fees. Mutual funds used in VIP accounts may charge a redemption fee if shares are redeemed
within a specified period of time. Clients may incur redemption fees in the event that an investment
model is updated. Redemption fees vary by mutual fund and are described in each fund’s prospectus.
Custodians and broker-dealers may be paid certain fees relating to these mutual funds, such as
networking or 12b-1 fees. The advisory fee may be negotiated in Varium Investment Partners’ sole
discretion.

Buy-List Provider Compensation

Out of its advisory fee, Varium Investment Partners pays the buy-list providers for their services the fee
in the table below, which is based on the total VIP assets.

        Account                    Annual Fee
        Assets                     Percentage

          First $100,000,000          0.30%
          Next $150,000,000           0.25%
          Next $250,000,000           0.20%
          Over $500,000,000           0.15%

The advisory fee for Buy-List Providers may be negotiated and a lower fee rate may be paid.

Compensation for the Sale of Securities

Neither Varium Investment Partners nor any of its supervised persons accepts compensation for the sale
of securities or other investment products, including asset-based sales charges or service fees from the
sale of mutual funds.

Item 7 Types of Clients
Client Description

Varium Investment Partners’ clients are individuals and may also include institutions such as financial
services firms, investment management firms, insurance companies, other registered investment
advisers, broker-dealers, and banks whose investor clients may consist of individuals, banks or thrift
institutions, pension and profit-sharing plans, trusts, estates, charitable organizations and corporations or
business entities.

General Requirements

Varium Investment Partners’ portfolio management services are generally offered to investors through

programs where the Financial Consultant of a third-party Firm or Sponsor provides advice to the client.
Financial Consultants are not employees of Varium Investment Partners but are independent or
employed by Sponsors and Firms typically not affiliated with Varium Investment Partners.

Generally, you should have a written agreement with your Sponsor and/or Financial Consultant. The
Financial Consultant collects financial and background information from the client, and assists in and is
responsible for identifying your investment objectives. The Financial Consultant recommends
strategies that are designed to meet those objectives. Your Financial Consultant is your primary contact
and he or she should report to you regularly.

Financial Consultants may utilize software and marketing and sales material and other documentation
provided by Varium Investment Partners to assist you in selecting the investment strategy which is
suitable for you.

Varium Investment Partners will receive your financial information from the Financial Consultant, your
custodian, the Sponsor or the broker-dealer, as applicable. In accordance with its fiduciary duty,
Varium Investment Partners reviews the account opening paperwork or Client profile information
provided by the Sponsor or your Financial Consultant to determine whether the selected Strategy is
suitable for the client. Varium Investment Partners reserves the right to request additional information
provided by the client. After Varium Investment Partners accepts the account for management, Varium
Investment Partners is granted investment discretion by the client and exercises such discretion in
management of the account.

Collateral Accounts

If an account is pledged as collateral for a loan, and if the lender has initiated a liquidation of securities
in the account pursuant to the terms of the collateral agreement, your account may not be invested in
accordance with the Strategy’s model portfolio and/or your investment objective for a period of time.
Varium Investment Partners reserves the right to cease management by terminating the advisory
agreement if, due to the constraints imposed by the collateral arrangement, the account cannot be
feasibly managed in accordance with the Strategy’s parameters.

U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) Sanctions Program

In compliance with the OFAC sanctions program, Varium Investment Partners or its designee will
check to verify that your name does not appear on OFAC’s “Specifically Designated Nationals and
Blocked Persons” List (“SDN List”). Your name will also be checked to verify that you are not from, or
engaging in transactions with people or entities from, embargoed countries and regions published on the
OFAC Web Site. Varium Investment Partners or its agent may access these lists through various
software programs to conduct these searches in a timely and accurate manner. Varium Investment
Partners or its designee will also review existing accounts against these lists when they are updated.

In the event Varium Investment Partners or its designee determines a Client, or someone with or for
whom the Client is transacting, is on the SDN List, or is from or engaging in transactions with a person
or entity located in an embargoed country or region, Varium Investment Partners will immediately
contact Varium Investment Partners’ Anti-Money Laundering and OFAC compliance group to
determine the proper course of action, which may include: rejecting the transaction and/or blocking the
Client’s assets, and; filing a blocked assets and/or rejected transaction form with OFAC.

Account Minimum Requirements

The account size minimum for the Varium Investment Partners Portfolios product is $100,000. At
Varium Investment Partners’ sole discretion, we may lower the account minimum.