Burnham & Company LLC

ITEM 5: FEES AND COMPENSATION
Advisory Services

Our fees are based on an annualized percentage of the market value of your portfolio’s assets under
our management. Our standard fee schedule for investment management services is:

                                   Assets Under Management

                      Under $1,000,000              1.25%
                      $1,000,000-$3,000,000         1.00%
                      Over $3,000,000               0.75%

We bill our fees quarterly, in advance, as specified in our investment management agreement with
you. We calculate our fee on the total market value of the securities, including bank deposits and
cash balances, under our management, as of the last trading day of the preceding quarter, as re-
ported by the account custodian. When our services are engaged any time other than the beginning
of a calendar quarter, our fees will be prorated. The prorated fee amount will be based on initial
deposit total market value as described above and time remaining in the quarter, as specified in
investment management agreement with you. We generally do not prorate our fees with respect to
additions to, or withdrawals from, your account during any quarter; however, fee adjustments may
be made on a case- by-case basis when appropriate and in consultation with you. We appreciate
advanced notice of anticipated additions or withdrawals so that we can better plan for the manage-
ment of your account.

Our investment management fees are negotiable and agreed upon at the time of our engagement.
We may agree to a fixed management fee for certain accounts. If you, your family or related per-
sons also have accounts under our management, those accounts may be aggregated for fee calcu-
lation purposes. We may negotiate our fees taking into consideration such things as the size of
your account, the number of managed portfolios, your relationship with other clients, the length of
our relationship with you, the complexity of your personal circumstances, the composition of your
portfolio, the complexity of investment strategies, the frequency of desired meetings or special
reporting, and other factors that affect our cost of providing services for you. For these reasons,
our fees may vary among clients who may appear to be in similar circumstances. Other investment
advisers may charge higher or lower fees for comparable services.

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Retirement Plan Consulting
Our fees are based on an annualized percentage of the market value of the retirement plan’s assets
as reported by the recordkeeper or custodian. Our standard fee schedule for retirement plan con-
sulting is:

                                    Assets Under Management

                       Under $1,000,000             0.80%
                       $1,000,000-$3,000,000        0.60%
                       Over $3,000,000              0.40%

Generally, we bill our fees quarterly, in advance, as specified in our retirement plan consulting
agreement with you. However, some recordkeeper may charge at a different interval. This will be
disclosed in the retirement plan consulting agreement. We calculate our fee on the total market
value of the securities, including bank deposits and cash balances, under our management, as of
the last trading day of the preceding quarter, as reported by the account custodian or recordkeeper.
When our services are engaged any time other than the beginning of a calendar quarter, our fees
will be prorated. The prorated fee amount will be based on initial deposit’s total market value as
described above and time remaining in the quarter, as specified in retirement plan consulting agree-
ment with you. We generally do not prorate our fees with respect to additions to, or withdrawals
from, your account during any quarter; however, fee adjustments may be made on a case-by-case
basis when appropriate and in consultation with you. We appreciate advanced notice of anticipated
additions or withdrawals so that we can better plan for the management of your account.

Our retirement plan consulting fees are negotiable and agreed upon at the time of our engagement.
We may negotiate our fees taking into consideration such things as the size of the plan, number of
participants, the number of portfolios, ERISA based services, the length of our relationship with
plan or the plan sponsor, the frequency of desired meetings or special reporting, and other factors
that affect our cost of providing services for you. For these reasons, our fees may vary among plans
that may appear to be in similar circumstances. Other investment advisers may charge higher or
lower fees for comparable services.

Direct Billing to Your Custodian or Recordkeeper

Generally, clients authorize us under our investment management agreement, retirement plan con-
sulting agreement, recordkeeper, and/or the custodian authorization form to directly deduct our fee
from their account(s). If you provide us with such authorization, your fee payment will show on
your custodian statement. You may terminate this fee deduction at any time by giving us written
notice. For investment management clients, you can direct us to withdraw the fees for multiple
accounts from a particular account. This can only be done with accounts titled the same. If you
request an invoice, your payment is due by check within 10 days following receipt of our billing
invoice.

Burnham and Company LLC                        Page 3                           ADV Part 2A – 7/8/26

Transaction Fees and Other Expenses

Our investment management fees and retirement plan consulting fees do not include brokerage
commissions, transaction fees, and other related costs and expenses incurred in connection with
providing our services to you. Notably, most custodians have now adopted zero-cost trading for
...

ITEM 7: TYPES OF CLIENTS

We provide investment management services to individuals, high net worth individuals, pension
and profit-sharing plans, trusts, estates, and charitable organizations, and companies. We do not
require a minimum account size to become a client.