Needham R B Advisory Corp

Item 5: Fees and Compensation
Fee Schedule - Investment Management
Fee Payment Options

As indicated in our advisory agreement with you, there are two options you may select to pay for our
services:

       Direct debiting (Preferred) – each month we will notify your custodian of the amount of the fee
       due. The custodian does not validate or check the calculation of our fee. The custodian will
       deduct the fee from your billing account. Each month you will receive a statement directly from
       your custodian showing all transactions. RBNAC will also send you a copy of the billing invoice
       sent to the custodian.

       Pay-by-check – we will issue you an invoice for our services monthly and you will pay us by
       check.

       We do not select other advisors for our clients and therefore do not include this service in our
       fee schedule.

       We view Cash as an asset class, and as such we include it in our fee calculation.
       Sometimes fees may exceed the yield on cash/money market fund.

Fees are billed monthly, in advance on the market value of the previous end of the month at the
following rates:

For clients of RBNAC prior to October 4, 2018:

       Account Asset Value Annual Fee
       Assets up to $2,000,000 1%
       Assets over $2,000,000 1/2 of 1%

       Minimum Annual Fee - $1,500.00
       No minimum account size

For clients of Kimball Capital Management prior to October 4, 2018:

       Account Asset Value Annual Fee
       Assets up to $2,000,000 1.25%
       Next $2,000,000 1.00%
       Next $5,000,000 .75%
       Next $15,000,000 .60%
       Over $25,000,000 .45%

       (Clients who were with KCM prior to 10/4/2018 continue to receive this fee schedule)

For clients of RBNAC after October 4, 2018:
        Account Asset Value Annual Fee
        Assets up to $2,000,000 1.00%
        Next $3,000,000 .75%
        Over $5,000,000 .50%

The cost of the annual surprise audit for certain accounts as mandated by the Custody Rule will be
shared equally by each of these “Custody Accounts”.

Advisory fees payable to us do not include all the fees you will pay when we purchase or sell securities
for your account(s). The following list of fees or expenses that can be charged by the broker/custodian
directly when a security is bought, sold, or held in your account(s). Other fees not listed here may also
be incurred and charged:

           •​ Brokerage commissions and markups

           •​ Transaction fees

           •​ Exchange fees

           •​ Advisory and administrative fees charged by Mutual Funds or Exchange Traded Funds

           •​ Advisory fees charged by sub-advisors (if used for your account)

           •​ Custodial fees

           •​ Deferred sales charges on mutual funds and annuities

           •​ Odd-Lot differentials

           •​ Transfer taxes

           •​ Wire transfer and electronic fund processing fees

We do not receive, directly or indirectly, any of these fees charged to you. They are paid directly to the
broker/custodian/mutual fund. In addition, we do not have any “employee” that receives any
compensation from purchase or sale of securities for your account.

We are a fee-only investment advisor. We do not have any potential conflicts of interest present
that relate to any additional (and undisclosed) compensation from you.

Other Fees and Expenses

Needham Advisory Corp. does not provide custodial services but will assist our clients in obtaining
suitable safekeeping services. There may be an additional charge by the custodian for these services.
Accounts custodied through Needham Advisory as part of a consultation arrangement will be billed an
annual administrative fee of $250.00.

For accounts which an officer of Needham Advisory serves as either sole or co-trustee,
additional expenses for the annual surprise audit as mandated by the Custody Rule, trust
income tax preparation, or other extraordinary services will be charged directly by the CPA, and
not by the firm, from the trust account. The firm will ensure that the payment is made through
the trust account and will not exceed 2.5% annually.

Investment Consultation

Investment consultation services are available at an hourly rate of $250.00. Consultation does not
include continuous supervisory services. The minimum fee per consultation is $250.00. Investment
consultation fees are payable upon completion of the consultation.

Financial Consultation

Financial consultation is available at an hourly rate of $250.00. For complex financial plans
Needham Advisory will provide a best effort estimate of the total fee in advance. Fees for financial
consultation are payable upon completion of the consultation.

For clients who seek Financial Planning, and do not engage in ongoing Investment Management,
there is a minimum flat-fee of $2500.

Item 6: Performance-Based and Side-By-Side
Management
Needham Advisory does not charge performance fees on a share of the capital appreciation of a
client’s account (performance-based fees). Our advisory fee compensation is charged only as disclosed
above in Item 5.

Item 7: Types of Clients
Needham Advisory provides services to a number of different types of clients, including:

           •​ Individuals, including high net worth individuals

           •​ Trusts, estates, and charitable organizations

           •​ Corporations or other business entities

           •​ Non-profit entities