BB Graham & Company Inc

Item 5. Fees and Compensation
Most BBG clients choose to have BBG advisory services, or a third-party program to manage their assets
in order to obtain ongoing in-depth advice. The scope of advisory services and corresponding fees is
outlined in an Advisor Agreement and is provided to the client in writing prior to the start of the
relationship.

Investment Management Fees

The annual Advisory Agreement fee is negotiated based on a percentage of the investable assets not to
exceed 2.99%.

*By this 2.99% fee, the adviser might charge fees higher than most investment advisers. Fees of 3% or
greater are in excess of the industry norm, and similar advisory services can be obtained for less.
The client will be asked to sign an agreement allowing the custodian to invoice the client’s account held
by the custodial broker dealer, but usually he / she will choose to have the custodial broker dealer
withdraw funds automatically.
BBG does not bill clients directly. RBC, the custodian, bills clients on behalf of the firm in relation to
programs made available through RBC. Third-party advisors bill their clients directly for all services and
provide any payment due BBG, pursuant to contractual or other agreement, directly to BBG.
Current client relationships may exist where the fees are higher or lower than the fee schedule above as
fees may be negotiated.
Although the Advisory Agreement is an ongoing agreement and constant adjustments are required, the
length of service to the client is at the client’s discretion. The client or the investment manager may
Form ADV Part 2A/B for BBG                                                                         Page 8 of 20
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terminate an Agreement by written notice to the other party. At termination, fees will be billed on a pro
rata basis for the portion of the quarter completed. The portfolio value at the completion of the prior full
billing quarter is used as the basis for the fee computation, adjusted for the number of days during the
billing quarter prior to termination.

Financial Planning Fees

The fees for a financial plan are predicated upon the facts known at the start of the engagement. For
financial planning services as provided by BBG, client may agree to pay BBG a minimum hourly fee of
$50.00 per hour which is negotiable. Hourly fees for financial planning services are negotiable and may
be higher depending on the complexity of the services and/or the advisory representative assigned to
your account. This hourly consultation service may take the form of general consulting and/or general
investment advice for individuals and/or institutions. It may also take the form of investment advice for
individuals or institutions that do not meet the minimum requirement for the investment management
service. Additionally, it may also take the form of corresponding and/or coordinating with attorneys, CPAs
and/or other professionals, as well as document production and other administrative services.

In the event that the client’s situation is substantially different than disclosed at the initial meeting, a
revised fee will be provided for mutual agreement. The client must approve the change of scope in
advance of the additional work being performed when a fee increase is necessary.
After delivery of a financial plan, future face-to-face meetings may be scheduled, as necessary.

Fees charged to clients may be higher or lower than the aforementioned fees depending on the nature of
any pre-existing relationship, the complexity of the accounts, or terms and conditions of any outstanding
or pre-existing verbal or written agreement to which BBG is a party.

As a result of managing clients’ accounts, clients may also incur brokerage and other transaction-related
fees. Clients are encouraged to carefully review Item 5 Fees and Compensation, Item 11 under
Participation/Interest in Client Transactions and Item 12 Brokerage Practices for further details on all fees
charged to clients.

Employer Sponsored Retirement Plan Consulting Services Fees

The negotiable Consulting Service Fee is calculated as an annual fee and will be paid quarterly. The
Consulting Service Fee is paid as a percentage of assets and is based on the fair market value of the
Included Assets in the Plan. BBG’s Advisory Fees may be paid: (i) by the Client (Plan Sponsor) directly;
or (ii) paid out of Plan assets pursuant to the Client’s written instructions to the Plan record keeper or
custodian to calculate and remit fees directly. Advisory Fees shall be prorated for partial quarters or
applicable fee calculation periods.

BBG’s Advisory Fees will be fully disclosed and transparent. There are no soft dollar, as that term is
defined under Section 28(e) of the Securities Exchange Act of 1934 ("Exchange Act"), or undisclosed fee
arrangements with any other plan service providers.

Except for the Consulting Service Fee, BBG does not reasonably expect to receive any other
compensation, direct or indirect, for its Services under this Agreement. If BBG receives any other
compensation for such services BBG will: (i) return the amount received back to the Plan; and (ii) disclose
the amount and nature of compensation to the Client.

Item 7. Types of Clients
BBG is a registered investment adviser firm that provides investment advisory services to individuals,
pension and profit-sharing plans, trusts, estates, corporations and small businesses (collectively referred
to as “Clients”).

Requirement for Opening Accounts (Minimum Investment Amount)

BBG’s fee range for each particular service is subject to negotiation and could vary depending upon
various circumstances, including the scope of the services to be provided (the minimum fees and fee
ranges for existing clients prior to current calendar year may differ from those indicated). However, BBG
may impose certain requirements for opening and/or maintaining an account, such as a minimum account
size or minimum fees and fee ranges.

The minimum investment required by an individual investor client is generally $50,000. Accounts below
these minimums may be negotiable and accepted on an individual basis at BBG's discretion. However,
BBG may from time to time establish, modify and waive account or investment minimums for different
investment products and/or services. Please see Fees and Compensation above for further details on
investment minimums.

Third-party programs may establish their required minimums.