Vista Investment Management LLC

Fees and Compensation
Fee Schedule
Vista is a fee-based adviser. Fees are based on a percentage of the dollar value of the amount of assets
under management.

Vista’s annualized fee schedule for portfolio management services is as follows:
    First $500,000 of assets under management ........................................ 1.00% per year
    Next $1,500,000 of assets under management .................................... 0.75% per year
    Balance over $2,000,000 of assets under management ....................... 0.50% per year
Assets under management are calculated based on total assets for the client relationship.
Vista has one pension consulting relationship for which it charges 0.05% of plan assets on an annualized
basis. The fee for these services is calculated by the plan administrator.

Payment of Fees and Other Costs to the Client
Compensation is payable quarterly at the end of each quarter. Clients have the option of paying fees by
check or by automatic deduction from the account if the brokerage where the account is held provides this
service. If the client has fees deducted from their brokerage account, the client will receive a copy of the
billing invoice prior to the deduction of the quarterly fees. A client may terminate the advisory contract
before the end of a quarter. Fees will be prorated in the event services are terminated prior to the end of a
quarter. Fees are negotiable.
Fees paid to the adviser for portfolio management do not include other related costs that the client may
incur. Such additional costs may include brokerage commissions or fees and mutual fund commissions or
fees. The adviser does not receive any portion of these commissions or fees and is compensated solely
through the investment advisory fee. Item 12 of this document further discusses Brokerage Practices.

Performance-Based Fees and Side-By-Side Management
Vista does not charge performance‐based fees.

Types of Clients
Vista offers its services to individuals, high net worth individuals, trusts and estates, and individual
participants of retirement plans. In addition, Vista offers services to businesses, charitable foundations,
and pension and profit sharing plans.

Account Requirements
Vista has a stated minimum account value of $1 million per client relationship. Client relationships often
include multiple accounts. The normal account minimum of $1 million is negotiable based upon the
adviser-client relationship and is at the sole discretion of the investment adviser.

Methods of Analysis, Investment Strategies, and Risk of Loss
Methods of Analysis and Investment Strategies
The adviser uses a variety of methods of analysis and information sources to manage client portfolios and
to provide research. The primary sources of information include research databases, Internet investment
sites, company filings, company news releases, conference calls with company management, and various
investment periodicals and third party research.
Vista’s equity strategy is to seek superior results by investing in securities that are undervalued in relation
to their earnings, cash flows, and growth rates. It attempts to minimize risk by maintaining a high degree

of diversification and through thorough analysis of securities used in portfolios. The security selection
process is driven by a fundamental analysis of each investment. Vista believes that success can be
achieved through patience, discipline, and the ability to think and act independently. Market timing does
not play a significant role in the investment process.
In managed portfolios, Vista uses various securities to achieve clients’ objectives within their risk
tolerance parameters. These securities include stocks, bonds, mutual funds, and exchange traded funds
(ETFs). Some of the funds may use derivative securities, such as options or futures contracts, and can
provide exposure to alternative asset classes, such as commodities, real estate, or volatility indices. The
adviser may also use inverse or leveraged ETFs. Inverse ETFs move in the opposite direction of an
underlying index. The advisor uses inverse ETFs primarily to adjust a client’s asset allocation as an
alternative to selling other securities, which would trigger tax consequences. In some situations,
leveraged ETFs may be used to magnify the ability to adjust asset allocation. In many cases, the use of
such securities by the adviser reduces overall portfolio risk by increasing diversification or lowering
equity exposure. The adviser does not use inverse or leveraged ETFs in a speculative manner.

General Risk of Loss Statement
Investors should carefully consider that investing in securities involves risk of loss which the investor
should be prepared to bear. In addition, investors should be aware that security markets experience
varying degrees of volatility, and over time a client’s portfolio value is likely to fluctuate and may at any
time be worth more or less than the amount originally invested.

Risks
Clients face various investment risks including loss of principal risk, market risk, interest-rate risk,
inflation risk, currency risk, reinvestment risk, and liquidity risk.