O'Keefe Stevens Advisory Inc

Item 5 - Fees and Compensation

Description of Fees
  Fees for OSA’s advisory services are established, on an individual basis, during
  personal consultations. Client goals, the amount of funds and the number of accounts
  are the major considerations. The Firm’s fees are reflective of OSA’s policy of
  providing personalized high-quality service to its clients.

   Fees charged by OSA for financial planning or consulting services are dependent upon
   the services rendered to the client and may be either fixed or hourly. The specific
   services in these areas elected by the client, and their respective fees, are defined in
   the Financial Planning and Consulting Services Agreement executed with the client
   upon engaging the services of the Firm. Fees for financial planning or consulting
   services may be negotiable at the discretion of the advisor and/or the Firm.

   For financial planning services, the fee assessed may be either a fixed one-time fee or
   a recurring annual fee within a range of $500 to $5000, depending upon specific needs
   defined by the client. Fees may also be adjusted upward or downward, at the
   discretion of the IAR, based upon the complexity of a client’s specific financial
   planning concerns revealed during subsequent discovery interviews.

   Consulting services generally entail ongoing discussions and/or reviews of generalized
   advisory issues not specifically related to financial planning or asset management (i.e.
   estate planning). These services are usually provided on a limited or ongoing basis, as
   defined by specific client needs and defined in their agreement. Clients are billed on
   an hourly fee basis at the Firm’s standard rate of $250 per hour, in fifteen (15) minute
   increments. These fees may also be waived, at the discretion of the IAR.

   Clients utilizing OSA’s ongoing asset management services are required to
   execute an Investment Management Agreement which defines the management
   services to be provided by the Firm and the asset management fee to be charged. The
   fee for these management services is based on a percentage of the market value of
   assets under management at the end of each calendar quarter and billed in advance for
   the next quarter.

   For the purpose of fee calculation, advisory and non-advisory client assets may be
   aggregated, affording the client the lowest fee percentage whenever possible. As
   previously noted, the Firm will, at its discretion, allocate client assets to management
   models mutually agreed upon with the client and consistent with each client’s
   suitability parameters.

   The information below discloses asset management fee arrangements for investment
   advisory clients of O’Keefe Stevens Advisory. Management fees may be negotiable,
   on a case-by-case basis and at the discretion of the advisor, based on the case
   complexity or specific needs of the client. When agreeing to become an asset

                              O’Keefe Stevens Advisory, Inc.

   management client of O’Keefe Stevens Advisory, your advisor will outline your
   specific fee arrangement in the Investment Management Agreement.

   As an investment advisory client of O’Keefe Stevens Advisory, you should expect to
   pay either a flat 1% fee or follow the tiered fee schedule outlined below. This will be
   negotiated and agreed to with your advisor based on your individual circumstances.

                 Account Value                           Annual Advisory Fee
                $ 0 to $ 250,000                               1.00%
                $ 250,001 to $ 1,000,000                       0.95%
                $ 1,000,001 to $ 3,000,000                     0.85%
                $ 3,000,001 to $ 5,000,000                     0.70%
                $ 5,000,001 to $ 10,000,000                    0.55%
                $ 10,000,001 and above                         0.37%

Fee Billing
   One-time fixed fees for financial planning services are 50% payable upon execution
   of the agreement with the balance due within thirty (30) days following the
   presentation to the client of the written financial plan or planning recommendations.
   Recurring annual fees are due in quarterly installments which will be either billed
   directly to the client or deducted directly from a client’s custodial advisory account.
   While clients are not required to implement their financial plan with the Firm, the fee
   for developing a financial plan may be waived or applied to ensuing asset
   management fees, at the discretion of the IAR of the Firm, should they elect to do so.

   Consulting services are billed to clients either upon completion of each specific
   consultation or cumulatively on a quarterly basis for ongoing consulting services, as
   specified in the client’s agreement. An up-front retainer may be required for these
   services, at the discretion of the advisor, with balances due as stated above for these
   services.

   As previously stated, should a client elect to terminate these services prior to the
   completion of the services contracted for, a prorated fee will be determined based on
   the time expended by the advisor up to the Firm’s receipt of a written termination
   notice from the client. An invoice reflecting the prorated fee based on the advisor’s
   hourly rate of $250 will be forwarded to the client, due and payable within fifteen
   (15) days of date of the invoice. The Firm will not refund any portion of financial
   planning or consulting fees or retainers which may have been paid in advance by the
    terminating client.

   All asset management clients are billed in advance each quarter for advisory services
   based on a percentage of each client’s assets under management on the last business
   day of each calendar quarter, as valued by the account custodian(s), according to the
   fee schedule above. As previously stated, managed and indirectly managed account
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Item 7 - Types of Clients
Description
    OSA’s clients are comprised primarily of individuals but may also include corporations,
    pension and profit-sharing plans, trusts, estates and charitable organizations. Client
    relationships vary in scope and length of service.

Account Minimums
    OSA does not require a minimum account size to engage a new client or retain an
    existing client. Advisory fees, however, do vary based on the amount of assets
    under management by the Firm and client with smaller accounts may pay a higher
    percentage rate on their annual fees than the fees paid by clients with greater assets
    under management.