Willow Creek Capital Management Inc

Item 5 Fees and Compensation
A. Fee Schedule

Portfolio Management Wrap fFees

Total Assets Under Management               Annual Fees
$0 - $4,999,999                             1.00%
$5,000,000 - $6,999,999                     0.80%
$7,000,000 – AND UP                         0.50%

The advisory fee is calculated using the value of the assets in the Account on the last business day of
the prior billing period. These fees are generally negotiable and the final fee schedule will be
memorialized in the client's Wrap Fee advisory agreement. Clients may terminate the agreement
without penalty for a full refund of WCCM's fees within five business days of signing the Investment
Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 5
days' written notice.

Pension Consulting Services Fees

Asset-Based Fees for Pension Consulting

Total Assets Under Management               Annual Fees
$0 - $4,999,999                             1.00%
$5,000,000 - $6,999,999                     0.80%
$7,000,000 – AND UP                         0.50%

The advisory fee is calculated using the value of the assets on the last business day of the prior billing
period.

These fees are generally negotiable and the final fee schedule will be memorialized in the client's
advisory agreement. Clients may terminate the agreement without penalty for a full refund of WCCM's
fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may
terminate the pension consulting agreement generally with 5 days' written notice.

B. Payment of Fees

Payment of Portfolio Management Fees
Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's
written authorization on a quarterly basis. Fees are paid in advance.

Payment of Pension Consulting Fees
Asset-based pension consulting fees are withdrawn directly from the client's accounts with client's
written authorization on a quarterly basis. Fees are paid in advance

C. Client Responsibility For Third Party Fees

Clients utilizing Wrap Fee portfolio management services should see the any applicable separate Wrap
Fee Program Brochure for additional details regarding third-party fees. Client accounts not participating
in the wrap fee program are responsible for the payment of all third third-party fees (i.e., custodian
fees, commissions, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate
and distinct from the fees and expenses charged by WCCM. Please see Item 12 of this brochure
regarding broker/custodian.[

D. Prepayment of Fees

Raymond James collects fees in advance. Refunds for fees paid in advance but not yet earned will be
refunded on a prorated basis and returned within fourteen days to the client via check, or return
deposit back into the client's account.

For all asset-based fees paid in advance, the refunded fee from RJ will be equal to the balance of the
fees collected in advance minus the daily rate* times the number of days elapsed in the billing period
up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-
based fee rate by 365.)

E. Outside Compensation For the Sale of Securities to Clients

Susan Ann Estep and David Anthony Weber are insurance agents. In this role, they accept
compensation for the sale of investment products to WCCM clients.

1. This is a Conflict of Interest
Supervised persons may accept compensation for the sale of investment products, including asset-
based sales charges or service fees from the sale of mutual funds to WCCM's clients. This presents a
conflict of interest and gives the supervised person an incentive to recommend products based on the
compensation received rather than on the client's needs. When recommending the sale of investment
products for which the supervised persons receives compensation, WCCM will document the conflict of
interest in the client file and inform the client of the conflict of interest.

2. Clients Have the Option to Purchase Recommended Products From Other Brokers
Clients always have the option to purchase WCCM recommended products through other brokers or
agents that are not affiliated with WCCM.

3. Commissions are not WCCM's primary source of compensation for advisory services

4. Advisory Fees in Addition to Commissions or Markups
Advisory fees that are charged to clients are not reduced to offset the commissions or markups on
investment products recommended to clients

Item 7 Types of Clients
WCCM generally provides advisory services to the following types of clients:

       Individuals
       High-Net-Worth Individuals
       Pension and Profit Sharing Plans
       Charitable Organizations
       Corporations or Business Entities

There is no account minimum for any of WCCM's services.