NBT Capital Management Inc

ITEM 5 - FEES AND COMPENSATION
Description of Fees
Within its traditional advisory services platform, NBTCM bases its fees on the Following methods,
depending upon the nature and complexity of the service being provided:

    •   A percentage of Assets Under Management (AUM);
    •   A fixed one-time project fee;
    •   Flat recurring retainer fees; and/or
    •   Hourly Fees.
Actual fee schedules were cited previously in the Types of Agreements section. As also previously stated,
fees may be negotiable and subject to change for a client as the scope and complexity of services
increase or decrease over time.
Some investment adviser representatives of NBTCM are also associated with LPL
Financial as broker-dealer Registered Representatives (“dually registered persons”). In their capacity as
Registered Representatives of LPL Financial, these dually registered persons may earn commissions for
the sale of securities or investment products that they recommend for brokerage clients. They do not,
however, earn commissions on the sale of securities or investment products recommended or purchased
in advisory accounts through NBTCM. Clients have the option of purchasing many of the securities and
investment products available through LPL Financial through another broker-dealer or investment advisor
should they choose to do so.
NRS basis its fees on a percentage of assets under management, hourly charges, and participant
statistics.

Fee Billing
Fees for Investment Management and Retirement Plan Consulting and Advisory Services provided by
NBTCM are billed quarterly, in arrears, meaning that we invoice clients after a three-month billing period
has ended, as opposed to in advance at the beginning of a billing period. Payment in full is expected upon
invoice presentation. Fees are usually deducted from a designated client account, with the consent of the
client, to facilitate billing efficiencies. Fees for Retainer Services are billed quarterly, in arrears.
NRS clients are billed quarterly, either in advance or in arrears, as agreed to in their Respective asset
management agreement. Fees may be paid by the plan sponsor (i.e. employer), the plan participants or a
combination of both according to ERISA rules and regulations.
Cleveland Hauswirth investment management fees are billed quarterly in advance, meaning that we
invoice clients at the beginning of the three-month billing period. Fees for the quarter are based on the
value of the individual account or qualified plan on the last day of the previous calendar quarter. Payment
in full is expected upon invoice presentation. The invoice will show the amount of the fee and the value of
the assets on which the fee was calculated. Fees may be billed to clients directly or may be deducted
from a designated investment account or retirement plan assets.
Clients must consent in advance to direct debiting of your investment account by initialing your billing
preference in the Investment Management Agreement.

                                       NBT Capital Management, Inc.

Other Fees
Costs and expenses typically borne by a client relating to its portfolio investments include: brokerage
fees, commissions and other related trading, execution, and settlement related costs and fees; custodial
fees; wire fees, banking fees, interest incurred on borrowings, if any; dividends paid on securities sold
short, governmental charges, taxes and duties; transfer fees, registration fees; interest expenses;
withholding taxes; other expenses associated with buying, selling or holding investments; and other costs
associated with such account. These fees will be paid by the client directly to the client-designated
custodian, broker-dealer, bank, or other third party, as applicable.
Custodians used by NBTCM, such as Schwab, may charge transaction fees on purchases or sales of
certain securities, including mutual funds and exchange-traded funds. These transaction charges, if
assessed, are usually small and incidental to the purchase or sale of a security and defined in the
respective custodian’s agreement, which is provided to and signed by the client prior to utilizing the
custodian. NBTCM, however, does not receive any portion of these fees, if charged by the custodian.
From an asset management standpoint, the selection of securities appropriate to a client’s portfolio and
their overall management plan is more important than these nominal fees, if any, that the custodian may
charge to buy or sell the securities selected. If charged by any custodians utilized by NBTCM, however,
they would be further discussed in the Brokerage Practices section of this Disclosure Document.

Expense Ratios
Most mutual funds and exchange-traded funds, whether purchased directly or through custodial accounts,
generally charge an internal management fee, called an expense ratio, which is separate from the
advisory service fees charged by NBTCM or transaction fees which might be charged by the custodians.
For example, an expense ratio of 0.50 means that the mutual fund company charges 0.50% for their
services. Performance figures quoted by mutual fund and exchange-traded fund companies in various
publications are after their fees have been deducted. These fees are specific to each fund and deducted
from the fund’s performance annually by the respective fund company. Clients are not billed directly for
these fees. Any such fees, if present, are clearly defined in each fund’s prospectus.
A client could also invest in these products through other brokers, agents, or investment advisers that are
not affiliated with NBTCM. Clients should evaluate the fees incurred in connection with these investment
vehicles and the advisory fees charged by NBTCM to fully understand the total amount of fees paid.
Neither NAAA nor its supervised persons accept compensation for the sale of securities or other
investment products, including asset‐based sales charges or service fees from the sale of mutual funds or
...

ITEM 7 - TYPES OF CLIENTS
Description
NBTCM’s traditional advisory clients are comprised primarily of individuals but may also include
employer-sponsored retirement plans, trusts and estates. Client relationships in this traditional platform
may vary in scope, complexity and length of service.
Clients eligible to enroll in the Firm’s digital advisory platform may include individuals, IRAs, and
revocable living trusts. Non-natural clients (i.e. corporations, partnerships, government entities) and
clients that are subject to the Employee Retirement Income Security Act of 1974 (ERISA), are not eligible
for the Digital Program.

NRS provides investment advice exclusively to the sponsors and/or trustees qualified and non-qualified
pension and profit-sharing plans. Client relationships vary in scope and length of service.
Cleveland Hauswirth generally provides investment management services and advice to individuals,
401(k) plans, pension and profit sharing plans, trusts, estates, or charitable organizations, corporations or
business entities. Each individual client’s needs are identified and addressed.

Account Minimums
For traditional NBTCM advisory platform clients, the minimum Investment Management account size is
$50,000 of assets under management, which equates to an annual fee of $500. If an account falls below
$50,000 in value, the minimum annual fee of $500 may be charged. Accounts of less than $50,000 may
be set up if the client and advisor anticipate the client will add additional funds to the accounts bringing
the total up to the minimum $50,000 within a reasonable time. Other exceptions may apply to employees
of NBTCM and to participants within 401(k), pension and profit-sharing client accounts. In addition, clients
with assets below the minimum account size may pay a higher advisory fee annual percentage rate for
their assets under management than clients with greater assets under management. NBTCM may, at its
discretion, waive or adjust these account minimums.
NRS does not require a minimum account size for retirement plan clients.

Cleveland Hauswirth has a minimum account size of $500,000 for individual clients and $2,000,000 for
retirement plan accounts for consideration for management services. CH has the discretion to waive the
account minimum. Other exceptions will apply to our employees and their relatives, or relatives of existing
clients.

                                        NBT Capital Management, Inc.