Borer Denton & Associates Inc

Item 5      Fees and Compensation
                       PORTFOLIO MANAGEMENT SERVICES FEES
The annualized fee for Portfolio Management Services is charged as a percentage of assets
under management, according to the following schedule:
Minimum Annual Charge                                      $2,500
 1.000% on the first                                   $1,000,000
 0.625% on the next                                    $4,000,000
 0.500% on the next                                    $5,000,000
To be negotiated                                       Above $10,000,000
Advisory fees do not include broker commissions or other transactions charges, custody fees
or other service charges assessed by third parties. Neither our firm nor individual
representatives receive any portion of such charges.
Fees are due in advance semi-annually and are billed or, with your permission, deducted from
your account at the custodian organization that holds your securities.
Borer Denton & Associates has not offered and does not offer Wrap Fee Programs nor do we
use the services of other investment advisers or impose any special charges for Separately
Managed Accounts beyond the schedule shown above.

Limited Negotiability of Advisory Fees: Although BDA has established the aforementioned
fee schedule, we retain the discretion to negotiate alternative fees on a client-by-client basis.
Client facts, circumstances and needs are considered in determining the fee schedule. These
include the complexity of the client’s financial circumstances, assets to be placed under
management, anticipated future additional assets; related accounts; portfolio style, account
composition, and reports, among other factors. The specific annual fee schedule is identified
in the contract between the adviser and each client.
We may group certain related client accounts for the purposes of establishing the minimum
account size and determining the annualized fee.
Discounted fee rates are offered to our associates and their family members who live in the
same household as the associated person.

                                  GENERAL INFORMATION
Termination of the Advisory Relationship: A client agreement may be canceled at any
time, by either party, for any reason upon receipt of written notice. As disclosed above,
certain fees are paid in advance of services provided. Upon termination of any account, any
prepaid, unearned fees will be promptly refunded. In calculating a client's reimbursement of
fees, we will prorate the reimbursement according to the number of days remaining in the
billing period from the date of receipt of the written cancellation notice.
Mutual Fund Fees: All fees paid to BDA for investment advisory services are separate and
distinct from the fees and expenses charged by mutual funds and/or ETFs to their

shareholders. These fees and expenses are described in each fund's prospectus. These fees
will generally include a management fee, other fund expenses, and a possible distribution fee.
If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A
client could invest in a mutual fund directly, without our services. In that case, the client would
not receive the services provided by our firm which are designed, among other things, to
assist the client in determining which mutual fund or funds are most appropriate to each
client's financial condition and objectives. Accordingly, the client should review both the fees
charged by the funds and our fees to fully understand the total amount of fees to be paid and
to evaluate the advisory services being provided.
Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible
for the fees and expenses charged by custodians and imposed by broker dealers, including,
but not limited to, any transaction charges imposed by a broker dealer that effects
transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item
12) of this Form ADV for additional information. Where certain mutual funds charge
additional fees in the form of fund marketing service fees (typically known as “12b1 fees”) to
be paid to the adviser, as a matter of policy such 12b1 fees are refunded to client accounts.
Grandfathering of Minimum Account Requirements: Pre-existing advisory clients are
subject to BDA's minimum account requirements and advisory fees in effect at the time the
client entered into the advisory relationship. Therefore, our firm's minimum account
requirements will differ among clients.
ERISA Accounts: BDA is deemed to be a fiduciary to advisory clients that are employee
benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement
Income and Securities Act ("ERISA"), and regulations under the Internal Revenue Code of
1986 (the "Code"), respectively. As such, our firm is subject to specific duties and obligations
under ERISA and the Internal Revenue Code that include among other things, restrictions
concerning certain forms of compensation. To avoid engaging in prohibited transactions, BDA
may only charge fees for investment advice about products for which our firm and/or our
related persons do not receive any commissions or 12b-1 fees, or conversely, investment
advice about products for which our firm and/or our related persons receive commissions or
12b-1 fees, however, only when such fees are used to offset BDA's advisory fees.
Advisory Fees in General: Clients should note that similar advisory services may be
available from other investment advisers for similar or lower fees.
BDA personnel are separately licensed as registered representatives of Henley & Company
LLC, an unaffiliated broker-dealer. These individuals, in their separate capacity, can effect
securities transactions for which they will receive compensation from commissions charged to
the account separate from advisory fees. Please see Item 10 for additional information
...

Item 7      Types of Clients
Borer Denton & Associates, Inc. provides advisory services to the following types of clients:
• Individuals (other than high net worth individuals)
• High net worth individuals
• Pension and profit-sharing plans (other than plan participants)
• Corporations or other businesses not listed above
BDA does not impose a minimum account size, but imposes a minimum annual fee of $2,500.
Minimum fees may be waived at BDA’s sole discretion in consideration of, among other
things, related accounts and anticipated future contributions.