High Falls Advisors Inc

Item 5 – Fees and Compensation
    Generally
       The specific way fees are charged by HFA is established in the client’s written advisory
       agreement with HFA. HFA will generally bill its fees on a quarterly basis. Clients are
       billed in arrears. Clients may elect to be billed directly for fees or to authorize HFA to
       directly debit fees from their accounts. Accounts initiated or terminated during a calendar
       quarter will be charged a prorated fee. Upon termination of any account any earned,
       unpaid fees will be due and payable.

        Account fees for accounts terminated before the end of a quarter are calculated as
        follows: 1.) Determine the average daily balance from the beginning of the quarter to the
        date of termination. 2.) Take that value and multiply by the annual fee set in the
        management contract. 3.) Divide that amount by 4 to determine the quarterly fee. 4.)
        Divide the quarterly fee by the number of days in the quarter to determine the daily rate.
        5.) Multiply the daily rate by the number of days actually managed in the quarter to
        determine the pro-rated fee.

        Account fees for accounts initiated after the start of the quarter are calculated as follows:
        1.) Determine the average daily balance from the date account is initiated to the end of
        the quarter. 2.) Take that value and multiply by the annual fee set in the management
        contract. 3.) Divide that amount by 4 to determine the quarterly fee. 4.) Divide the
        quarterly fee by the number of days in the quarter to determine the daily rate. 5.) Multiply
        the daily rate by the number of days actually managed in the quarter to determine the pro-
        rated fee.

        HFA’s management fees are exclusive of brokerage commissions, transaction fees, and
        other related costs and expenses which may be incurred by the client. Clients may incur
        certain charges imposed by custodians and/or brokers, as specified in the
High Falls Advisors, Inc.
SEC File # 801-34161                                                                           Page 7

        custodian/broker agreement. Mutual funds and exchange traded funds also charge
        internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees
        and commissions are exclusive of and in addition to HFA’s fee.

       Portfolio Management

        The annual fee for Investment Services is charged as a percentage of client assets under
        management, billed quarterly in arrears.

        The basic fee schedule is as follows:

            Assets under Management (AUM)                Annual Fee
            $ 0 to $ 1,500,000                           1.00%
            $ $1,500,001 to 3,000,000                    0.75%
            Over $3,000,000                              0.50%

        Although High Falls Advisors, Inc. has established the above fee schedule, we retain the
        discretion to negotiate alternative fees on a client-by-client basis.

        Some existing clients fall outside our basic fee schedule, based on prior negotiated
        arrangements.

        The fee is specified in the client’s advisory agreement. Fees are computed on the average
        daily balance for the quarter. Fees are prorated for clients not in the service the entire
        quarter. Annual fees are divided by four and charged quarterly.

        In some cases, clients are billed on an agreed retainer/flat fee for portfolio management.
        Such arrangement would be set forth in the advisory agreement.

        Multiple accounts in one household can be combined for break point discounts.

       Fees for Financial Planning Services

        A flat annual fee is quoted based on the complexity of the case. Clients are invoiced and
        50% payment is expected at the start of the engagement and final payment at the end of
        year 1. In certain cases, clients may pay monthly. The fee is reassessed annually unless
        the client terminates the planning services.

        Fees range from $2,500.00 to $ 20,000.00 depending on the complexity.

High Falls Advisors, Inc.
SEC File # 801-34161                                                                        Page 8

       Fees for Tax Preparation

          Preparation fees are based on the time and complexity of the return. Clients are
          invoiced and payment is expected upon completion of the tax return. The minimum fee
          for tax preparation is $ 1050.00. Fees can range from $ 1050.00 to $15,000.00
          depending on complexity. The minimum fee for wealth management clients of the firm
          is $ 575.00.

          Although our base fee for the 2026 tax year is $ 1050.00 for tax-only clients and $ 575
          for wealth management clients, we retain the discretion to negotiate fees on a client-by-
          client basis

Item 7 – Types of Clients
HFA provides management services to individuals, high net worth individuals, small businesses,
charitable organizations and trusts. Most HFA clients are individual investors.

HFA sets a minimum account size of $ 100,000.00 for most Portfolio Management Services,
although there may be exceptions which are evaluated on a case-by-case basis.