John E Sestina and Company

Item 5: Fees and Compensation

A. Fee Schedule

      Full Service Financial Planning Fees
      John E. Sestina and Company's Full Service Financial Planning fee is determined based on a net
      worth schedule. Account values are based upon the values (market value or fair market value in the
      absence of market value) of the client's accounts at the beginning of the relationship or at the client's
      annual renewal. All fees are agreed upon prior to entering into a contract with any client.
      The minimum annual fee for the first tier ($0-$500,000) has increased from $3,000 to $4,000. This

change is effective on April 1, 2022 for all new clients. All existing clients prior to April 1, 2022
are grandfathered at the prior minimum fee of $3,000.

         Net Worth Amount                                Minimum Annual Fee
         $0.00 - $500,000.00                             $4,000
         $500,000.01 to $1,000,000.00                    $5,000
         $1,000,000.01 - $1,500,000.00                   $6,000
         $1,500,000.01 - $2,000,000.00                   $8,250
         $2,000,000.01 - $2,500,000.00                   $10,000
         $2,500,000.01 - $3,000,000.00                   $12,500
         $3,000,000.01 - $3,500,000.00                   $15,000
         $3,500,000.01 - $4,000,000.00                   $17,500
         $4,000,000.01 - $4,500,000.00                   $20,000
         $4,500,000.01 - $5,000,000.00                   $22,500
         $5,000,000.01 - $6,000,000.00                   $25,000
         $6,000,000.01 - $7,000,000.00                   $30,000
         $7,000,000.01 - $8,000,000.00                   $35,000
         $8,000,000.01 - $9,000,000.00                   $40,000
         $9,000,000.01 - $10,000,000.00                  $45,000
         $10,000,000.01 +                                Negotiable
Individual Portfolio Management Fees
 All assets under management are typically charged a 1% annual fee. In some cases this could be
     as high as 2% based on amount of client assets under management. The advisory fee is
        calculated using the average daily balance of the account during the billing period.
The fees for all services are generally negotiable and the final fee schedule is presented to each
client. Clients may terminate the agreement without penalty for a full refund of John E. Sestina and
Company's fees within five business days of signing the Investment Advisory Contract or Financial
Planning Agreement. Thereafter, clients may terminate the Investment Advisory Contract
immediately upon written notice.

“Individual Portfolio Management” services are included at no additional cost to those engaging in
Full Service Financial Planning with John E. Sestina and Company and is included as part of the
annual Full Service Financial Planning Fee.

B. Payment of Fees

      Payment of Full Service Financial Planning Fees
      Our Full Service Financial Planning fees are calculated and charged on a fixed fee basis and are
      typically collected quarterly. The annual fee will be billed in four equal installments. One fourth
      of the annual fee is due and payable upon acceptance of the Financial Planning Services Agreement
      and the remaining balance will be equally billed and payable quarterly. In certain circumstances,
      we may permit clients to pay their advisory fees on a monthly basis but in no event will the fees be
      prepaid more than six months in advance.
      Client has the option to authorize fees to be paid directly through a brokerage account or with
      AdvicePay
      Payment of Individual Portfolio Management Fees
      Asset-based portfolio management fees are withdrawn directly from the client's accounts with
      client's written authorization on a monthly basis. Fees are paid in arrears.

C. Client Responsibility For Third Party Fees

      Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees,
      mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees charged
      by John E. Sestina and Company. Please see Item 12 of this brochure regarding broker-
      dealer/custodian.

D. Prepayment of Fees

      John E. Sestina and Company collects fees in advance. Should service be terminated by either party,
      refunds for fees paid in advance will be returned within thirty days to the client via check.

E. Outside Compensation For the Sale of Securities to Clients

      Neither John E. Sestina and Company nor its supervised persons accept any compensation for the
      sale of investment products, including asset-based sales charges or service fees from the sale of
      mutual funds.

                      F. Non-Discretionary 3(21) Fiduciary Services

      When the Adviser performs “3(21) Fiduciary Services,” the Adviser will act as a co-fiduciary
      “investment adviser” that provides “investment advice” as defined under Section 3(21) of ERISA.
      Under this arrangement the Adviser is appointed by the plan sponsor or trustee to determine a
      recommended lineup of investments to be included in the Plan. These recommendations are

presented to the Plan Sponsor, who has the ultimate responsibility to accept or reject the
recommendation. The Adviser will not have any further responsibility to communicate
instructions to any third‐party, including the custodian, and/or third‐party administrator. The
Adviser will not communicate directly with the recordkeeper regarding administrative and
recordkeeping matters arising under the Adviser’s investment advisory agreement with the Plan
Sponsor, or more generally about the recordkeeper’s services to the Plan.
The Adviser will provide the Plan Sponsor with a sample investment policy statement. Each
retirement Plan Sponsor should adopt a final investment policy statement (“IPS”) which serves as
...

Item 7: Types of Clients

John E. Sestina and Company generally provides advisory services to the following types of clients:
                ❖      Individuals
                ❖      High-Net-Worth Individuals

            •   John E. Sestina and Company has updated Financial Planning service, which includes
                investment advice, is subject to a minimum annual fee of $4,000. This minimum may be
                waived on a case by case basis. This fee may be negotiated from time to time for family,
                friends, and existing prior personal relationships.

        •   Fees for financial planning services including individual portfolio management will be paid
            via check or with AdvicePay unless you specify a(n) account(s) that allow(s) John E.
            Sestina and Company to directly debit the fee from that account on a monthly basis
            according to the corresponding fee amount on the net worth fee schedule. Fees paid via
            check or AdvicePay are invoiced and to be paid quarterly.

        •   Individual Portfolio Management service is subject to a minimum invested amount of
            $100,000. This minimum may be waived on a case by case basis. This fee may be
            negotiated from time to time for family, friends, and existing prior personal relationships.

        •   Fee for Individual Portfolio Management will be directly debited from the account(s) being
            managed on a monthly basis. Fees will begin being collected once the account is opened
            and funded according to the fee schedule known as 210.

        •   The tiered fees corresponding to Fee Schedule 000 are:
                                       $0.00 and above : 000 Basis Points

        •   The tiered fees corresponding to Fee Schedule 025 are:
                                       $0.00 and above : 25 Basis Points

        •   The tiered fees corresponding to Fee Schedule 050 are:
                                       $0.00 and above : 50 Basis Points

        •   The tiered fees corresponding to Fee Schedule 075 are:
                                       $0.00 and above : 75 Basis Points

        •   The tiered fees corresponding to Fee Schedule 100 are:
                                       $0.00 and above : 100 Basis Points

        •   The tiered fees corresponding to fee schedule 210 are:
                                       $0.00-$1,000,000.00 : 100 Basis Points
                                       $1,000,000.01-$2,000,000.00 : 75 Basis Points
                                       $2,000,000.01 + : 50 Basis Points