Lebenthal Diversified Asset Management Inc

Item 5 Fees and Compensation
Fees for Sub-Advisory Asset Management Services
The Primary Adviser will be charged an asset-based fee ("Advisory Fee") in advance on a quarterly basis.
LDAM's Advisory Fee for portfolio management ranges up to 2.00%. The Advisory Fee will be calculated based
on the value of the assets managed on the last day of the previous quarter, as determined by the account
custodian. The Advisory Fee is subject to negotiation between LDAM and the Primary Adviser.

The Advisory Fee only covers the portfolio management services provided by LDAM. The Advisory Fee does
not include administrative services, costs for trade execution of transactions through the broker-dealer and
custodial services, which are charged by the Client's designated broker-dealer or assumed by the Primary
Adviser.

Qualified Retirement Plan Services
Since the advisory services we provide to each Qualified Retirement Plan is customized, our fees will be
negotiated with the plan sponsor or named fiduciary on a case-by-case basis.

Clients may terminate the pension consulting services agreement upon 30 days written notice to our firm. Clients
will incur a pro rata charge for services rendered prior to the termination of the agreement, which means they will
incur advisory fees only in proportion to the number of days in the quarter. If pre-paid advisory fees are paid that
we have not yet earned, Clients will receive a prorated refund of those fees.

Additional Fees and Expenses
As part of our investment advisory services, we may invest, or recommend that Clients invest, in mutual funds
and exchange traded funds. The fees that are paid to our firm for investment advisory services are separate and
distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund's
prospectus) to their shareholders. These fees will generally include a management fee and other fund
expenses. When Clients are not participating in a wrap fee program they will also incur transaction charges
and/or brokerage fees when purchasing or selling securities. When Clients are participating in a wrap fee
program, the Primary Investment Adviser will incur the transaction charges and/or brokerage fees when
purchasing or selling securities. These charges and fees are typically imposed by the broker-dealer or custodian
through whom account transactions are executed. We do not share in any portion of the brokerage
fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total costs,
Clients should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. For
information on our brokerage practices, refer to the Brokerage Practices section of this brochure.

Compensation for the Sale of Securities
Certain persons providing investment advice on behalf of our firm are registered representatives with Lebenthal
Financial Services LLC ("LFS"), a securities broker-dealer, and a member of the Financial Industry Regulatory
Authority and the Securities Investor Protection Corporation. In their capacity as registered representatives, these
persons receive compensation in connection with the purchase and sale of securities or other investment products,
including asset-based sales charges, service fees or 12b-1 fees, for the sale or holding of mutual funds.
Compensation earned by these persons in their capacities as registered representatives is separate and in addition
to advisory fees. This practice presents a conflict of interest because persons providing investment advice to
advisory Clients on behalf of our firm who are registered representatives have an incentive to recommend
investment products based on the compensation received rather than solely based on Client needs.

While persons providing investment advice to advisory Clients on behalf of our firm can select or recommend
mutual fund investments in share classes that pay 12b-1 fees, it is our policy that these persons do not select or
recommend share classes that pay 12b-1 fees for advisory account. However, in the event that we inadvertently
receive a 12b-1 fee on an advisory account, we will rebate the 12b-1 fee to advisory accounts. However, it is
important to note that these persons, when acting in their separate capacities as registered representatives, can
select or recommend mutual fund investments in share classes that pay 12b-1 fees when Clients are eligible to
purchase share classes of the same funds that do not pay such fees and are less expensive. This presents a conflict
of interest. Clients are under no obligation, contractually or otherwise, to purchase securities products through
any person affiliated with our firm who receives compensation described above.

Compensation for the Sale of Insurance Products
Certain persons providing investment advice on behalf of our firm are licensed as independent insurance agents.
These persons will earn commission-based compensation for selling insurance products, including insurance
products they sell to you. Insurance commissions earned by these persons are separate and in addition to our
advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf

of our firm who are insurance agents have an incentive to recommend insurance products for the purpose of
generating commissions rather than solely based on Client's needs. Clients are under no obligation, contractually
or otherwise, to purchase insurance products through any person affiliated with our firm.

Item 7 Types of Clients
We offer investment advisory services to other investment advisers, as sub-advisors. We also provide advisory
services to pension and profit-sharing plans, including Taft Hartley plans (collectively "the Plan"). Depending on
the scope of the advisory agreement with the Plan, we may also be engaged by the Plan to offer certain assistance
to plan participants. In doing so, the plan participants are not considered clients of LDAM.

We do not impose a minimum investment account size to start and maintain an advisory relationship.