Macnealy Hoover Investment Management Inc

Item 5      Fees and Compensation

       How are we paid for our services ?

       Our fee schedule is based upon the value of the securities and cash under supervision
 at the end of the preceding calendar quarter and will be calculated at the following rates unless
 modified by mutual agreement.

              0.75 % per annum on the first million dollars
              0.50 % per annum on the next two million dollars
              0.40 % per annum on the next two million dollars
              0.35 % per annum on all assets over five million dollars

 Unless mutually agreed otherwise, MHIM requires a minimum account relationship of $ 500,000.
 MHIM, in its sole discretion, may charge a lesser investment management fee and/or reduce or waive
 its aggregate portfolio minimum based upon certain criteria ( i.e. anticipated future earning capacity,
 anticipated future additional assets, dollar amount of assets to be managed, related accounts,
 account composition, negotiations with client, etc.) As a result of the above, similarly situated clients
 could pay different fees. In addition, similar advisory services may be available from other investment
 advisers for similar or lower fees. We have some accounts that have negotiated lower rates and/or
 pay a predetermined flat rate per quarter.

 Fees will be payable quarterly in advance and will be calculated on the total market value of all
 related accounts. The initial fee will be prorated to the end of the current quarter. You can choose
 to have your fees deducted from your accounts or to pay us separately.

 The investment agreement may be terminated by either you or by us at any time, without penalty,
 upon written notice effective upon receipt. In the event of such termination, fees will be
 reimbursed to you on a pro rata basis, the unearned portion of the prepaid fee, calculated from the
 start of the quarter to the date your/our actual receipt of termination notice.

          Layering of Fees

      All mutual funds, money market funds, and ETF's have internal management/operating fees.
 When MHIM charges an investment management fee on these investment vehicles, you are in
 essence paying twice for the management of assets.
      MHIM does not receive any brokerage commissions.
      MHIM does not receive any compensation from mutual funds, ETF's or money market funds.
      MHIM does not receive any compensation other than our management fees.

TradeAway/Prime Broker Fees. Relative to its discretionary investment management services, when
beneficial to the client, individual equity and/or fixed income transactions may be effected through
broker-dealers other than the account custodian, in which event, the client generally will incur both
the fee (commission, mark-up/mark-down) charged by the executing broker-dealer and a separate
“tradeaway” and/or prime broker fee charged by the account custodian.

Item 7     Types of Clients

       What are the general characteristics of our client base ?

        As of December 31, 2018, MHIM had 84 account relationships. The majority of these clients
 are high net worth individuals. (financial assets in excess of $ 1,000,000 ) We may manage their
 trust, IRA's, joint accounts etc. We also manage three profit-sharing retirement plans, two non-
 high net worth account relationships, and one nonprofit organization’s endowment. While each
 client has their own unique investment objectives, our clients generally prefer a traditional,
 conservative approach to generating income and growth, rather than more speculative investment
 alternatives. To paraphrase a client, " We have made our money. Your job is to minimize our losses,
 yet keep pace with inflation.”