Leigh Baldwin & Co LLC

ITEM 5 FEES AND COMPENSATION

Traditional LBA Managed Account

Compensation for advisory services is a flat percentage based on assets undermanagement computed using the
closing account balance on the last business day of the previous quarter. Maximum Fees in a traditional managed
account are as follows; all fees are subject to negotiation. Total ticket charges (commissions and service fees) and
other fees may also apply, see item 12 brokerage practices. Management fees will be deducted or billed quarterly
four times per year.

               Value of Managed Assets                                                   Annual Fee

                     $0 to $250,000                                                        1.55%

                  $250,001 to $500,000                                                     1.50%

                  $500,001 to $1,000,000                                                   1.25%

                     over $1,000,001                                                       1.00%

Hybrid LBA Accounts

In our legacy negotiated hybrid models, stock commissions and other fees may be used in conjunction with a
management fee. Management fees would not be charged on the value of these positions that have incurred
commissions. Typically, management fees in this type of arrangement are assessed on Mutual Fund positions.
Accounts are billed on the same schedule as Traditional LBA Managed Accounts.

Use of Altruist Financial LLC as a Custodian

In addition to National Financial Services LLC, the Firm makes Altruist Financial LLC (“Altruist”) available as a
qualified custodian for certain managed accounts. Altruist is an unaffiliated SEC‑registered broker‐dealer and
FINRA/SIPC member that provides custodial, trading, and account administration services. Clients may be offered
the ability to custody assets at Altruist based on account characteristics, client preferences, and the Firm’s
determination of the most appropriate custodial platform for the client’s needs. The management fee will be
tiered according to AUM, this means that as your assets exceed a certain level, subsequent assets over that level
will be charged a lower annual percentage rate, but assets below that level will continue to be charged the original
annual percentage rate. The fee is calculated based on the average daily net asset value of the account, billed
monthly in arears.

Altruist LLCʼs Model Marketplace fees and tax management tool fees – each of which range between 0.00% and
1.00% and are listed in the Altruist Fee Schedule available at www.altruist.com/legal – are automatically deducted
from the Advisorʼs house account or, according to the instruction of LBA.

                                                    Leigh Baldwin & Co., LLC
                                             112 Albany Street, Cazenovia, NY 13035                               6
                                       1 (800) 659-8044 | www.leighbaldwinadvisory.com

               Value of Managed Assets                                                    Annual Fee

                      $0 to $250,000                                                         1.55%

                   $250,001 to $500,000                                                      1.50%

                  $500,001 to $1,000,000                                                     1.25%

                      over $1,000,001                                                        1.00%

Altruist One Platform

Certain accounts custodied at Altruist may be eligible for participation in the Altruist One platform. Altruist One
provides enhanced account features, which may include tax‑aware portfolio management tools and enhanced
cash management options. The Altruist One platform results in an additional platform fee to the Firm of
approximately 0.12% of assets under management. The Firm does not charge clients an additional advisory fee for
participation in the Altruist One platform and absorbs this cost. As a result, a client’s advisory fee schedule is not
increased solely because an account is placed on the Altruist One platform.

Tiered Fee Accounts through Fidelity Managed Account Xchange (FMAX)

Available as an addendum to our traditional management agreement. The client’s management fee will be billed
monthly according to the Statement of Investment Selection (SIS) through the FMAX program. The fee will be
tiered according to AUM, this means that as your assets exceed a certain level, subsequent assets over that level
will be charged a lower annual percentage rate, but assets below that level will continue to be charged the original
annual percentage rate. The fee is calculated based on the average daily net asset value of the account, billed
monthly in advance. FMAX is structured by Fidelity Institutional Wealth Advisor LLC (FIWA) as a wrap program that
bundles investment advice, transaction services, custody and other administrative expenses for a fee disclosed in
the SIS which ranges from .10% to .22%. LBA, as an intermediary to this program, may charge additional fees for
services it performs in addition to the program fee (see Section 5, page 8 for a description of these possible fees; if
part of this program, please refer to FIWA Form ADV “Other Issues Related to Fees”) FIWA structures the wrap
account, LBA may utilize this as part of their managed program as the advisor intermediary.

Management Fee and Minimum Annual Fee Schedules:

               Value of Managed Assets                                                    Annual Fee

                      $0 to $250,000                                                        1.55%

                   $250,001 to $500,000                                                     1.50%

                  $500,001 to $1,000,000                                                    1.25%

                      over $1,000,001                                                       1.00%
...

ITEM 7 TYPES OF CLIENTS

Leigh Baldwin & Co., LLC provides portfolio management services to individuals, high net worth individuals,
corporate pension and profit-sharing plans, Taft-Hartley plans, charitable institutions, foundations, endowments,
municipalities, and trust programs. We do impose a minimum account size aggregate of $50,000 to be in the LBA
Managed Account Program unless otherwise permitted by upper management. For accounts that are referred to
outside SEC registered RIA’s, there is no minimum other than those imposed by those third-party RIA’s and which
is outlined in their own ADV’s. In some cases, we may elect not to take on a client because we do not feel we are
est suited to meet their investment needs. Also, we may end a client relationship if we feel we can no longer meet
their investment needs. We try to accommodate a wide range of custodians; however, we may refuse a client who
does not use a suggested/recommended custodian.

ITEM 8 METHOD OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS

Leigh Baldwin & Co., LLC’s investment analysis includes Fundamental and Technical Analysis. Fundamental
Analysis is rooted in mathematical and objective information. Since this type of analysis is heavily based on publicly
available information, risks may lay in the quality, publicity and truthfulness of the data provided. Technical
Analysis relies on charting patterns in stocks, following volume and price and may result in a short-term purchase
rather than a long-term hold due to a change in the charting. Technical trading eliminates external drivers, such as
fundamental trading, and focuses on past prices and volume to calculate current and future patterns. By using a
combination of these two strategies, the goal of the IAR is to have the discipline to buy fundamentally positive
stocks, when the charting works in their favor.

We will use a combination of long- and short-term purchases for portfolio management. Most securities are
bought with expectations that they will be held for over one year as a long-term purchase, but market conditions
may warrant a sale sooner than that holding time frame and the securities may be liquidated any time after
purchase.

Dollar Investment Club (DINC) is our branded systematic investment plan identified ultimately as a systematic
investment plan which combines exchange traded funds, mutual funds and individual equities designed to be
purchased at regular intervals. Leigh Baldwin is the sole investment advisor on these strategies.

You can find more information at www.dollarinvestmentclub.com. Though this has been implemented with the
target to be focused on systematic investing, the strategies and investment policies imposed are also suitable for
one-time purchases of varying amounts.

Investing in securities involves risk of loss that clients should be prepared to bear.

We may use options as part of the investment program, and certain options strategies may bear more risk than
others. If the investment account warrants a call writing strategy on its portfolio securities it limits its opportunity
to profit. If the investment account warrants a purchase of a put option it may lose the entire premium paid for a

                                                     Leigh Baldwin & Co., LLC
                                              112 Albany Street, Cazenovia, NY 13035                                 10
                                        1 (800) 659-8044 | www.leighbaldwinadvisory.com

put option. You would expect to generate premiums from a sale of call options. These premiums typically will
result in short-term capital gains for federal income tax purposes. In addition, stocks that are hedged with put
options may not be eligible for long term capital gains. This investment strategy may not be designed for investors
seeking a tax efficient investment and may or may not be used in your specific account.