VETA Investment Partners LLC

Item 5. Fees and Compensation
This section details the fees and compensation we receive for our services. Lower fees for comparable
services may be available from other advisers. The exact fees and other important terms will be outlined
in the Agreement between you and Veta.

We will typically be compensated for our advisory services for Clients, in one of several ways:

    •   Fees based on a percentage of assets subject to Veta’s services, calculated according to the
        market value of the Client’s underlying portfolio (in the case of institutional insurance company
        Clients, typically the value of the derivatives notional generated from hedging the underlying

        annuity contracts). Each Client has the opportunity to review and negotiate their Agreement with
        us prior to selecting our hedging services for their account.

   •   Fixed fees for periodic services, where the fee approximates the cumulative expected hourly rate
       for each Veta employee for the expected time spent. Fixed fees are negotiated with the Client in
       advance.

Fees charged for our model portfolio solutions and asset allocation services are negotiable by each Client
based on several factors, including the type of Client, the complexity of the Client's situation, the
composition of the Client's account, the potential for additional funding, the total amount of assets under
management, and the selected portfolio(s). Veta, in its sole discretion, reserves the right to offer an
advisory fee discount, which includes waiving a portion or all of the advisory fee for a period of time or
until an asset threshold is reached.

We bill institutional clients for fees incurred. As we do not have custody of Client assets, we do not
deduct fees from Client accounts. Institutional clients are billed in arrears, typically monthly or quarterly,
based on the average daily balance of the account(s) for the billing period. Fees are prorated based on
the number of days service is provided during the initial or final billing period.

Either we or the Client can terminate an advisory contract by giving the other party advance written
notice according to the terms of our Agreement. Although we do not solicit or require prepayment of
fees from our Clients, any fees paid in advance will be prorated to the date of termination and any
unearned portion thereof will be returned to the Client.

You may incur fees in addition to ours, such as custodian fees or mutual fund expenses. You will also
incur brokerage and other transaction costs; these are discussed in more detail in Item 12 of this
Brochure. Where requested, we will provide you with an estimate of the cost of a particular service.

We do not accept compensation for the sale of securities or other investment products, including asset-
based sales charges or service fees from the sale of mutual funds.

At times, we impose a minimum advisory fee in order to cover the costs of our investment advisory
services. The minimum fee is specific to each type of service and dependent on a variety of factors,
economies of scale and the cost of third-party services needed to render Veta’s advisory services. All
such fee arrangements are disclosed to you prior to our engagement and subject to negotiation. We may
aggregate accounts to meet minimum account minimums; whether we aggregate accounts will be
determined on a case-by-case basis and, again, is disclosed to you and subject to negotiation.

Item 7. Types of Clients
Veta will primarily provide investment advisory services to institutional Clients (as defined in Item 4,
“Clients”).

Minimum account sizes vary by investment strategy. We may waive these minimums at our discretion,
or aggregate related accounts to meet minimum account sizes. We may also at times impose a minimum
advisory fee in order to cover the costs of our services.
Our investment management or similar Agreements with Clients, which include investment guidelines,
are negotiated to incorporate mutually acceptable terms. Under these Agreements, Clients can impose
limitations on our investment discretion, such as restrictions regarding investments in certain securities
or types of securities.