Wealthharbor Capital Group LLC

Item 5 – Fees and Compensation

        Client fees will be billed in advance and calculated as of the last business day of each
calendar quarter based on the closing market value for the quarter (as determined in good
faith by WCG) of the assets in the Account. The management fee for WCG managed assets is
one and one half percent (1 1/2%) per annum charged quarterly. Fees are negotiable and
may be discounted at the discretion of WCG. Typically, these fees are deducted directly
from the assets of client accounts but a special arrangement may be made to bill the clients
directly. This fee will not include transaction-clearing costs that will be charged by the
custodian. This fee is approximately$12.00- $20.00 per trade but may be amended by the
clearing firm from time to time. WCG does not receive any portion of this fee and does not
control the clearing firm’s fee structure for trades other that WCG’s ability to replace a

clearing firm that charges fees excessive in the view of WCG. WCG will use no-load or NAV
trades of load mutual funds and does not receive 12b-1 fees for individually managed
accounts paid directly by mutual fund companies . The fee for the initial or terminating
calendar quarter will be pro-rated for the number of days which the Agreement was in
effect and any refunds will be returned to client accounts prior to account transfer to the
new custodian. WCG will receive no start-up or termination fees, nor will the client be
subject to any penalties unless pre-stipulated by the custodian.

       Additions to the account between billing periods may be charged a pro rata
management fee, at the discretion of WCG, in the same fashion as the Initial Fee described
above.

       Increases in the Management Fee will only be implemented at the beginning of a
new quarter and upon completion of a new client agreement. Reductions in fees will take
place at the beginning of the next calendar quarter.

      WCG may offer clients management services through other investment advisory
products such as variable annuities with no CDSC. Appropriate disclosure and fee
documents from registered advisers will be provided when used by WCG.

        Daily valuation retirement plan clients are charged on a quarterly basis in arrears.
The management fee for these plans is 1.5% of assets per annum charged quarterly. This
fee is negotiable and may be modified at the discretion of WCG depending on the specific
factors of the case. These plans also incur fees from custodians, record keepers, and third
party administrators; and these fee are either directly billed to the clients, deducted from
their assets, or paid out of the management fee charged by WCG depending on the
negotiated contract details for the client. In any case, these fees are fully disclosed to the
plan sponsor and participants. All mutual fund credits including 12-b1 fees and Sub TA fees
are returned to the plan to offset the disclosed management fees.

        WCG fees are exclusive of brokerage commissions, transaction fees, and other
related costs and expenses, if any. Any such fees, determined by the custodian, shall be
incurred by the client. Clients may incur certain charges imposed by custodians, brokers,
third party investment and other third parties such as fees charged by managers, custodial
fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions. Mutual funds and exchange traded funds also charge internal management
fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are
exclusive of and in addition to WCG’s fee, and WCG shall not receive any portion of these
commissions, fees, and costs.

WealthHarbor may also charge a negotiated flat dollar fee per quarter.

Item 7 – Types of Clients

       WCG provides portfolio management services to individuals, high net worth
individuals, corporate pension and profit-sharing plans, charitable institutions,
foundations, endowments, trusts, estates, corporations, and 401(k) plans.

       WCG manages Employee Retirement Income Security Act of 1974, as amended,
(“ERISA”) assets in the Alta Trust WealthHarbor Conservative Growth Fund and the Alta
Trust WealthHarbor Moderate Growth Fund (“CITs”). The CITs are bank maintained and
not registered with the Securities and Exchange Commission. The CITs are not a mutual
fund registered under the Investment Company Act of 1940, as amended, (“1940 Act”) or
other applicable law, and unit holders are not entitled to the protections of the 1940 Act.
The regulations applicable to the CITs are different from those applicable to a mutual fund.
The CIT’s units are not securities registered under the Securities Act of 1933, as amended
or applicable securities laws of any state or other jurisdiction.

       Minimum Initial Account Value is $100,000. WCG may, under certain circumstances,
waive the minimum account value.