Arnold Castellano and Associates LLC

Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
 ASSET MANAGEMENT
 ACA offers discretionary direct asset management services to advisory Clients. ACA charges
 an annual investment advisory fee based on the total assets under management as follows:
                Assets Under Management                     Annual Fee
                    Up to $1,000,000                          1.00%
                $1,000,001 to $2,000,000                      0.75%
                  $2,000,001 and above                        0.50%

 This is a flat fee/breakpoint fee schedule, the entire portfolio is charged the same asset
 management fee. For example, a Client with $750,000 under management would pay
 $7,500 on an annual basis. $750,000 x 1.00% = $7,500.
Clients have the following payment options:
   •   Monthly in arrears;
   •   Quarterly in arrears on the last business day of each quarter;
   •   Semi-annually in arrears on May 1 and November 1.
Fees will be based on the amount of assets managed as of the close of business on the last
business day of the previous period.
Lower fees for comparable services may be available from other sources. Clients may
terminate their account within five (5) business days of signing the Investment Advisory
Agreement with no obligation and without penalty. After the initial five (5) business days,
the agreement may be terminated by ACA with thirty (30) days written notice to Client and
by the Client at any time with written notice to ACA. For accounts opened or closed mid-
billing period, fees will be prorated based on the days services are provided during the
given period. All unpaid earned fees will be due to ACA. Client shall be given thirty (30)
days prior written notice of any increase in fees. Any increase in fees will be acknowledged
in writing by both parties before any increase in said fees occurs.
ACA may also utilize the services of a Sub-Advisor to manage Clients’ investment portfolios.
ACA will enter into Sub-Advisor agreements with other registered investment advisor
firms. When using Sub-Advisors, the Client will pay additional fees of up to 0.60% annually.
The Sub-Advisors fees are not included in the total fee disclosed by ACA. Sub-Advisor
directly deducts their portion of the fee separately from ACA.
The Management Fee will be pro-rated and billed, in arrears, at the end of each quarter
based on the average portfolio value which is calculated as follows:
Average portfolio value for any quarter is equal to the average of the following four values:
   1. Portfolio value at beginning of period.
   2. Portfolio value at end of month 1.
   4. Portfolio value at end of month 2.
   5. Portfolio value at end of quarter.
The Management Fee is calculated by multiplying one quarter (1/4) of the Annual Rate by
the Average Portfolio Value. All values include cash and accrued interest and are valued
according to trade date data delivered by the Custodian. Pursuant to the terms of the Client
Agreement, Client shall authorize and direct the Custodian (as defined) (a) to pay to
Subadvisor the Management Fee out of the Account upon the Custodian's receipt of a
statement therefore from Subadvisor, and (b) to deliver to Client at least quarterly a
statement of the amounts disbursed from the Account, including the Management Fee. No
increase in the Annual Rate shall be effective without prior written notification.
Orion Portfolio Solutions
ACA charges an annual investment advisory fee based on the total assets under
management of 1%. Lower fees for comparable services may be available from other
sources. OPS does not receive any portion of the advisory fee charged by ACA. The
investment management fees charged by Orion Portfolio Solutions are exclusive of, and in
addition to, Advisor’s investment advisory fee set forth above. The fees are charged

monthly in arrears and are based on the average daily account balance for the period for
the prior month.
Fees for OPS services include:
   •   Administration Fees (reporting and accounting services – ranging from 0.09% -
       0.32%),
   *Any accounts that are custodied at Fidelity will have an additional 0.05% added to
   each tier listed above.
   •   Account Maintenance Fees ($25 or $50 per account annually), and
   •   Strategist Fees (range from 0.0% to 0.20%).
   •   Separately Managed Account (SMA) Fees (range from 0.35% to 0.70%)
Fees are automatically deducted from the Client’s account by OPS; OPS will pay Advisor
their portion of the fees. Advisor does not have the ability to directly deduct their advisory
fee from the Client account.
Clients may terminate their account within five (5) business days of signing the Investment
Advisory Agreement with no obligation. For accounts closed mid-month, ACA will be
entitled to a pro rata fee for the days service was provided in the final month. Client shall
be given thirty (30) days prior written notice of any increase in fees. Any increase in fees
will be acknowledged in writing by both parties before any increase in said fees occurs.
ERISA PLAN SERVICES
The annual fees are based on the market value of the Included Assets and will not exceed
1%. The annual fee may be charged as a percentage of the Included Assets or as a flat fee.
Fees may be charged quarterly or monthly in arrears or in advance based on the assets as
calculated by the custodian or record keeper of the Included Assets (without adjustments
for anticipated withdrawals by Plan participants or other anticipated or scheduled
transfers or distribution of assets). If the services to be provided start any time other than
the first day of a quarter or month, the fee will be prorated based on the number of days
remaining in the quarter or month. If this Agreement is terminated prior to the end of the
billing cycle, ACA shall be entitled to a prorated fee based on the number of days during the
fee period services were provided or Client will be due a prorated refund of fees for days
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Item 7: Types of Clients
Description
 ACA generally provides investment advice to individuals, high net worth individuals,
 corporations and pension plans. Client relationships vary in scope and length of service.
Account Minimums
 ACA requires a minimum of $100,000 to open an account. In certain instances, the
 minimum account size may be lowered or waived.