Keating Investment Counselors Inc

Item 5         Fees and Compensation
The exact manner in which fees are charged is established in a client’s written agreement. However, the
general fee structures are outlined below.

           Investment Supervisory Services (“ISS”) Individual Portfolio Management
The annualized fee for Investment Supervisory Services will be charged as a percentage of assets under
management, subject to negotiation in limited circumstances and are based on the following fee
schedule:

                  Assets Under Management                                   Annual Fee
               Up to $1,500,000 market value                                     1.25%
               From $1,500,000 to $3,000,000 market value                       1.00%
               From $3,000,000 to $5,000,000 market value                        0.75%
               Above $5,000,000                                                 0.60%
               Minimum Quarterly Fee is $500
The client will be invoiced quarterly, semi-annually, or annually, in arrears. Invoices are calculated based
on the closing market value on the last business day of the applicable billing period (or 3, 6, or 12 months)
excluding accrued interest. Fees will be assessed pro-rata in the event the Portfolio Management
Agreement is executed at any time other than the first day of the billing period. When a client transitions
from the prior calculation method, which was based on the closing market value on the last business
day of the second to last month in each billing cycle (quarterly, semi-annually, or annually), the fees for
the transition month (example October 2024 for accounts billed through November 30, 2024) will utilize
the prior calculation method. Fees for November and December 2024 will be prorated based on the new
calculation method. As this new calculation method is effective in tiers, some clients may continue to be
billed under the prior calculation method during the transition. All clients will transition to the new
calculation method, which is completely in arrears using the value of the last pricing day of the last
month, by May 2025.
Effective January 1, 2025, only invoices with a value of $25 or more will be charged. Historically, we
have rounded fee invoice amounts to the nearest whole dollar depending on whether the cent amount
was above or below 50 cents. Effective August 1, 2022, we started billing clients in exact change.
KICI calculates the closing market value using a third-party portfolio management system. We reconcile
client accounts to their custodian/brokerage statements daily. The portfolio management system’s
values may differ from the custodian’s statement market value for various reasons, including accounting
methods (e.g. transactions posting on trade date versus settlement date) and pricing sources utilized.
KICI considers cash an asset class. We manage cash to control downside risk for clients. The fee
charged on an account could effectively be higher than the return on any asset class.
A minimum of $1,000,000 of assets under management is required for this service. This account size is
negotiable under certain circumstances. KICI can group certain related client accounts to achieve the
minimum account size and determine the annualized fee. For example, we could group accounts
belonging to a married couple together.
For those clients who desire that our advisory fees to be paid directly from their investment portfolio, we
will only do so when the following conditions are met:
   •   You provide our firm with written authorization permitting the fees to be paid directly from your
       account held by the qualified custodian.
   •   We send you an invoice showing the amount of the fee, the value of the assets on which the fee
       is calculated, and the specific manner in which the fee was calculated.
   •   The qualified custodian agrees to send you a statement, at least quarterly, indicating all amounts
       disbursed from your account including the amount of the advisory fee paid directly to our firm.
In limited circumstances, the scope and complexity of the client’s financial situation could require
additional time/resources outside the scale of the previously described services. In such cases, where
such additional services would be considered extraordinary, KICI would notify the client that an additional

fee, based on a negotiated rate, would be charged.
At the discretion of KICI, fees may be waived in certain circumstances, such as the timing of funding an
account or other reasons. Clients will be notified of any fee waivers applicable to their accounts.

Hourly charges: Keating Investment Counselors does not hold itself out as a financial planner.
However, we can provide financial planning related services incidental to the portfolio management
services previously disclosed. Those individuals who require advice on a single aspect of the
management of their financial resources can retain KICI on a short-term, general consulting basis to
address specific areas of concern. KICI’s hourly fee for general consulting services is typically $350 per
hour, which is billed upon completion of the consultation.
We have an inherent conflict of interest whenever we provide financial planning services to a client who
also has retained our portfolio management services. It could be in our best interest not to recommend
paying down debt that would directly reduce the Assets Under Management that we manage and charge
a percentage fee for. We mitigate this conflict by documenting conversations with clients using
correspondence, reports outlining the financial planning areas addressed, and investment policy
statements.
Whenever we provide financial planning Services, we shall:
  1. Document the scope of work in an addendum to our current portfolio management agreement
  2. Prepare a questionnaire to understand the client’s needs
...

Item 7        Types of Clients
KICI provides advisory services to the following types of clients:
       Individuals, including High Net Worth Individuals
       Trusts, Estates and Charitable Organizations

       Pension and Profit-Sharing Plans (Other than Plan Participants)

Please see Item 5 for more information about minimum account size.