Pricing

Billing Procedures

Investment Management Services Billing
The fees for investment management services are billed and due monthly in arrears. Accordingly, we will transmit our advisory fee calculations electronically to the account custodian no later than three (3) days after the end of the preceding month. Fee calculations are based on the value of the account(s) as listed on a national securities exchange or the principal market where the securities are traded, at the closing price, as of the last business day of the month and as provided by the account custodian. Additionally, with respect to fixed income securities, valuations for billing often include accrued interest. Furthermore, margin interest, if applicable, will accrue monthly.

By agreement and a client’s written authorization incorporated in our investment management agreement, advisory fees are deducted directly from the client’s specified account(s).

Other Fees & Expenses

Clients will also incur additional third-party fees and expenses (“third party fees”) related to the management of investments and advisory service provisions. These fees may include but are not limited to no-load mutual fund ticket charges, brokerage transaction costs, deferred sales charges on previously purchased mutual funds, IRA maintenance fees, and other legal or transfer fees. The account custodians, broker-dealers, mutual fund companies, and others who provide account services charge these fees, and clients are responsible for payment of all third- party fees and expenses. Please note that as of the date of this Brochure, our account custodian does not assess transaction costs trades in equity securities (i.e., stocks, exchange-traded funds, etc.). Also, clients whose assets are invested in mutual funds, exchange-traded funds, money market mutual funds, closed-end funds, and other investment company securities will incur additional expenses. These are direct expenses of the investment company that issues the security but a cost that is borne by investors (clients). The specific fees and expenses are outlined in the prospectus for each investment company security.

It is important to note that the advisory fees paid to our firm are separate and distinct from the maintenance fees and transaction expenses charged by these third parties. Please also refer to Item 12, Brokerage Practices, for more information regarding our account custodian.

Refund Policy

Either party may terminate our investment management agreement at any time by providing thirty (30) days advance written notice to the other party. Upon our receipt of a termination request, we will assess advisory fees pro-rata, if applicable, to the date of receipt of notice of termination. Any unearned portion of prepaid advisory fees will be refunded within ten (10) days of the date of termination. Any balances for unpaid advisory fees due to our firm will be collected prior to the disbursement of funds, if applicable. In the event we are unable to deduct final fees from the account(s), in the case of an account transfer, we will transmit an invoice to the Client, which is due upon receipt. Clients pay final invoices by mailing a check to our address herein.

Other Compensation

Neither our firm nor management personnel accepts any compensation for the sale of securities or other investment products.