Walsky Investment Management Inc

Item 5          Fees and Compensation
INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO
MANAGEMENT FEES

The annualized fee for Investment Supervisory Services is charged as a percentage of assets under
management, according to the following schedule:

        Assets Under Management                   Annual Fee
        First $250,000                            1.4%
        Next $250,000                             1.0%
        Balance over $500,000                     .8%

Fees are negotiable for fixed income portfolios or accounts in excess of $3,000,000.

Our fees are billed quarterly, in advance, at the beginning of each calendar quarter based upon the
value (market value or fair market value in the absence of market value), of the client's account at
the end of the previous quarter. Fees will be debited from the account after we provide written notice
to the custodian of the amount of the fee to be deducted, in accordance with the client authorization
in the Client Services Agreement, unless another arrangement is requested by the client. We will
provide the client with a quarterly written invoice itemizing the fee, including the method used to
calculate the fee, the time period covered by the fee, and the amount of assets under management on
which the fee was based.

A minimum of $250,000 of assets under management is required for our services. This account size
may be negotiable under certain circumstances. Walsky Investment Management, Inc. may group
certain related client accounts for the purposes of achieving the minimum account size and
determining fees.

Limited Negotiability of Advisory Fees: Although Walsky Investment Management, Inc. has
established the aforementioned fee schedule, we retain the discretion to negotiate alternative fees on
a client-by-client basis. Client circumstances are considered in determining the fee schedule; these

factors may include the assets to be placed under management, related accounts and account
composition, among other factors. The specific annual fee schedule is identified in the contract
between the adviser and each client. Discounts, not generally available to our advisory clients, may
be offered to family members and friends of associated persons of our firm.

PUBLICATION OF PERIODICALS OR NEWSLETTERS

Our quarterly newsletter is provided free of charge to all advisory clients.

GENERAL INFORMATION

Termination of the Advisory Relationship: A client agreement may be canceled at any time, by
either party, for any reason. As disclosed above, certain fees are paid in advance of services provided.
Upon termination of any account, any prepaid, unearned fees will be promptly refunded. In
calculating a client’s reimbursement of fees, we will prorate the reimbursement according to the
number of days remaining in the billing period.

Mutual Fund Fees: All fees paid to Walsky Investment Management, Inc. for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds to their
shareholders. These fees and expenses are described in each fund's prospectus. These fees will
generally include a management fee, other fund expenses, and a possible distribution fee. If the fund
also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest
in a mutual fund directly, without our services. In that case, the client would not receive the services
provided by our firm which are designed, among other things, to assist the client in determining
which mutual fund or funds are most appropriate to each client's financial condition and objectives.
Accordingly, the client should review both the fees charged by the funds and our fees to fully
understand the total amount of fees to be paid by the client and to thereby evaluate the advisory
services being provided.

Wrap Fee Programs and Separately Managed Account Fees: We do not use wrap fee programs or
separately managed account services; therefore, there are no fees associated with these arrangements.

Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the
fees and expenses charged by custodians and imposed by broker dealers, including, but not limited
to, any transaction charges imposed by a broker dealer with which an independent investment
manager effects transactions for the client's account(s). Please refer to the "Brokerage Practices"
section (Item 12) of this Form ADV for additional information.

Grandfathering of Minimum Account Requirements: Pre-existing advisory clients are subject to
Walsky Investment Management, Inc.'s minimum account requirements and advisory fee schedules
in effect at the time the client entered into the advisory relationship. Therefore, our firm's minimum
account requirements may differ among clients.

ERISA Accounts: Walsky Investment Management, Inc. is deemed to be a fiduciary when advising
companies on employee benefit plans pursuant to the Employee Retirement Income and Securities

Act ("ERISA"). As such, our firm is subject to specific duties and obligations under ERISA that
include, among other things, restrictions concerning certain forms of compensation. To avoid
engaging in prohibited transactions, Walsky Investment Management, Inc. may only charge fees for
investment advice about products for which our firm and/or our related persons do not receive any
commissions or 12b-1 fees, or conversely, investment advice about products for which our firm
and/or our related persons receive commissions or 12b-1 fees, however, only when such fees are used
to offset Walsky Investment Management, Inc.'s advisory fees. (Our firm currently does not receive
any commissions or 12b-1 fees.)

Advisory Fees in General: Clients should note that similar advisory services may (or may not) be
available from other registered (or unregistered) investment advisers for similar or lower fees.
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Item 7           Types of Clients
Walsky Investment Management, Inc. provides advisory services to the following types of clients:

        •   Individuals (other than high net worth individuals)
        •   High net worth individuals
        •   Pension and profit-sharing plans (other than plan participants)
        •   Charitable organizations
        •   Corporations or other businesses not listed above

As previously disclosed in Item 5, our firm has established certain minimum account requirements
for an initial account and to maintain an account, based on the nature of the service(s) being provided.
For a more detailed understanding of those requirements, please review the disclosures provided in
each applicable service.