Bruce & Co Inc

Item 5 Fees and Compensation

INVESTMENT SUPERVISORY SERVICES ("ISS")

INDIVIDUAL PORTFOLIO MANAGEMENT FEES

Our annual fees for Investment Supervisory Services are based upon a percentage of assets

under management and generally range from 0.00% to 0.60%.

The annualized fee for Investment Supervisory Services are charged as a percentage of

assets under management, according to the following schedule:

Assets Under Management Annual Fee

First $500,000 0.6 of 1.0%

$500,000 to $1,500,000 0.5 of 1.0%

Over $1,500,000 0.4 of 1.0%

Clients are invoiced in arrears at the end of each calendar quarter based upon the value

(market value or fair market value in the absence of market value, plus any credit balance or

minus any debit balance), of the client's account at the end of the previous quarter.

Limited Negotiability of Advisory Fees: Although Bruce & Co., Inc. 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, assets to be placed under

management, anticipated future additional assets; related accounts; portfolio style, account

composition, reports, among other factors. We may group certain related client accounts for

the purposes of achieving the minimum account size requirements and determining the

annualized fee. We have offered investment advisory services for fixed fees.

Discounts, not generally available to our advisory clients, may be offered to family members

and friends of associated persons of our firm.

MUTUAL FUND PORTFOLIO MANAGEMENT FEES

Bruce & Co., Inc. charges an asset-based fee for this service. The fee arrangement,

termination, and refund policies are described in the Mutual Fund's prospectus and

Statement of Additional Information ("SAI").

GENERAL INFORMATION

Termination of the Advisory Relationship: A client agreement may be canceled at any

time, by either party, for any reason.

Mutual Fund Fees: All fees paid to Bruce & Co., Inc. 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 by the client and to thereby 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 with

which an independent investment manager effects transactions for the client's account(s).

Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional

information.

Grandfathering of Minimum Account Requirements: Pre-existing advisory clients are

subject to Bruce & Co., Inc.'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: Bruce & Co., Inc. 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. Bruce & Co., Inc. may only charge

fees for investment advice and does not receive any commissions or 12b-1 fees.

Advisory Fees in General: Clients should note that similar advisory services may (or may

not) be available from other registered (or unregistered) investment advisers for similar or

lower fees.

Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of

fees in advance of services rendered.

Item 7 Types of Clients

Bruce & Co., Inc. provides advisory services to the following types of clients: .

Individuals (other than high net worth individuals) .

High net worth individuals .

Investment companies(including mutual funds) .

Trusts, estates, or charitable organizations.