Wittenberg Investment Management Inc

Item 5 Fees and Compensation

    Advisory Fees and Compensation

    Investment advisory fees are paid quarterly in arrears pursuant to the terms of the
    investment advisory agreement. Investment advisory fees are based on the market value
    of assets under management at the end of each month or, in some cases, at the end of
    each calendar quarter. Management fees are collected in arrears after the end of each
    quarter. Most clients arrange for Wittenberg to deduct fees directly from their accounts.
    In the alternative, clients may elect to be invoiced and submit payment.

    Our annual fees for investment advisory services are based upon a percentage of assets
    under management and generally range from 1.00% to 1.50%.

    The annualized fee for investment advisory services is charged as a percentage of assets
    under management, according to the following schedule:

           Assets Under Management                          Annual Rate

                  First $500,000                               1.50%

                  Assets exceeding $500,000                    1.00%

    The investment advisory fee in the first quarter of service is pro-rated from the inception
    date of the account to the end of that quarter. All securities held in accounts managed by
    Wittenberg are independently valued by the custodian, designated by the client, typically
    Charles Schwab & Co. Wittenberg does not have the authority or responsibility to value
    portfolio securities.

Item 7         Types of Clients

     Wittenberg provides advisory services to the following types of clients:

     •    Individuals (other than high net worth individuals)
     •    High net worth individuals
     •    Non-profit organizations

     Wittenberg has a minimum requirement of $1,000,000 for opening and maintaining an
     account. This minimum can be waived at Wittenberg’s discretion.