Lefavi Wealth Management Inc

Fees and Compensation – Item 5

Investment Management
      For those clients who contract with the Adviser for Investment Management Services, the
      Adviser will charge a standard investment management fee of one percent (1%), factored
      against the value of assets under management in a client’s account. Fees may be
      negotiated by the client, but in no case will exceed 1.75% of the value of assets under
      management. Fee calculations are made on the last business day of the calendar quarter
      by factoring the fee percentage against the value of the assets in the investment account
      and dividing the product of the calculation by 4. For accounts opened during the quarter,
      the fee will be prorated for that quarter according to the number of calendar days the
      account was under management. For clients terminating accounts before the end of a
      quarter, the portfolio value will be determined at the end of the prior full billing quarter,
      prorated by the number of days the account was managed during the quarter.

      The Adviser and its affiliate, Bruce A. Lefavi Securities, Inc. (“BLS”) do not charge a
      commission for executing trades or for customary transaction costs like clearing firm
      ticket charges, postage and handling fees, exchange fees and other fees generated by
      executing trades in advisory accounts by BLS. Other fees might be charged and not
      otherwise paid by the firm, such as SEC charges.

      Clients who have previously paid commissions to BLS as part of executing transactions
      recommended by the Adviser do not incur an investment management fee for those
      products. In cases where a client’s account contains products on which a commission was

       paid to BLS, the Adviser will not include the commissioned product value when computing
       the quarterly fee for assets under management.

       In no instance will a client pay both a management fee to the Adviser as well as a
       commission paid to BLS for product execution. Clients should understand, however, that
       the fee waiver by the Adviser applies solely to products executed through the Adviser’s
       affiliate, BLS. Where a client has chosen a broker-dealer other than BLS to purchase or
       sell products, the Adviser will continue to charge its asset management fee as calculated
       above on all assets, including those assets not purchased at BLS.

       There is currently no minimum account size or minimum fee. Without limitation, the
       Adviser may waive investment fees and BLS may waive commissions on recommended
       products for employees of the Adviser and their families or families of existing clients.

Financial Planning
       Financial planning is available to all advisory clients. There is no additional fee for financial
       plans – it is offered alongside our Investment Management Services for our standard 1%
       annual fee on assets under management.

       For individuals who are not advisory clients, compensation for financial planning including
       the creation of a financial plan, are agreed upon at the commencement of the
       engagement, usually during the first meeting of the client and the Adviser’s
       representative. This compensation is a flat fee for described services or may, in some
       instances, be based on an hourly rate for service. If the scope of the engagement changes
       during the course of creating the plan, the fee arrangement may be renegotiated to
       reflect the change. A Financial Planning Engagement ends upon delivery of a financial
       plan. Further services, as necessary, may be furnished after delivery of the financial plan.
       Compensation for such services is billed separately and is in addition to compensation for
       the financial plan.

       For individuals interested in becoming advisory clients, financial plans are often offered
       free of charge to determine whether there is a potential fit for advisory services.

Fee Billing
       Investment management fees are billed quarterly, in advance. This means LWM invoices
       clients at the beginning of each billing period. Payment in full is expected upon invoice
       presentation. Fees are normally deducted from the client account to facilitate billing as
       authorized by the investment management agreement. However, clients may also pay
       by check.

       Fees for financial plans are initially billed at half of an agreed upon flat fee in order to
       commence work, and, upon delivery of the financial plan, an invoice for the balance is
       presented. If hourly rates are charged, the Adviser and client may otherwise agree on the
       method of payment.

Other Compensation
     Affiliated Broker-Dealer
            It is our business practice to avoid purchasing products which pay a
            commission to our affiliated broker-dealer. However, BLS may
            erroneously receive overrides, reallowances, or trailing fees in
            conjunction with selling insurance products or alternative investments to
            advisory clients. Any compensation received in this manner will be
            returned to the issuer or to the advisory client. If BLS earned a
            commission on past investments clients will not pay a management fee
            on that investment.

            Clients are always free to purchase products from another, unaffiliated,
            broker-dealer.

     Other Fees
            Clients will likely incur fees from non LWM affiliated brokerage firms,
            custodians, administrators and other service providers. These fees are
            charged by the service provider, not LWM or BLS. The amount and nature
            of these fees is based on the service provider’s fee schedule(s) at the
            provider’s sole discretion. These fees are separate and distinct from any
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Types of Clients – Item 7

      The Adviser primarily provides advice to individuals, however, may also advise pension
      and profit-sharing plans, trusts, estates, charitable organizations, corporations, or
      business entities. Client relationships vary in scope and length of service.

Methods of Analysis, Investment Strategies and Risk of Loss – Item 8