Palumbo Wealth Management LLC

Item 5 – Fees and Compensation

The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client shall sign one or more agreements that detail the responsibilities of PWM and the Client.

                                           Palumbo Wealth Management, LLC
                                 1010 Northern Boulevard, Suite 310 Great Neck, NY 11021
                                       Phone: (516) 629-7073 | Fax: (516) 829-0731
Page 7                                           www.palumbowm.com

A. Fees for Advisory Services
Wealth Management Services / Investment Management Services
Wealth management and investment management (herein “Advisory”) fees are paid quarterly, in advance of each
calendar quarter, pursuant to the terms of the Advisory agreement. Advisory fees are based on the market value of
assets under management at the end of the prior quarter. Advisory fees range from 0.15% to 1.75% annually based
on several factors, including, but not limited to: the services offered to the Client, the complexity of the services to be
provided, the level of Client assets managed by the Advisor, and/or the overall relationship with the Advisor. Advisory
fees for Clients selecting standalone investment management may be discounted compared to the fees charged for
wealth management services. The complexity of the Client relationship and the Client’s overall needs will determine
the investment management fee rate determined by the Advisor.

The Advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the
first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration
the aggregate assets under management with Advisor. All securities held in accounts managed by PWM will be
independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to
ensure accurate billing. For certain non-custodial partnership investments which are not held at the Custodian, the
Advisor may not receive quarter-end valuations prior to its fee billing calculation. In such instances, the Advisor will
bill on the committed capital during the first year of the investment. Beginning in the second year, the advisory fee
will be calculated using the most recent valuation provided by the third-party valuator.

Clients may make additions to and withdrawals from their account[s] at any time, subject to PWM’s right to terminate
an account. Additions may be in cash or securities provided that PWM reserves the right to liquidate any transferred
securities or decline to accept particular securities into a Client’s account[s]. Clients may withdraw account assets
on notice to PWM, subject to the usual and customary securities settlement procedures. However, PWM designs its
portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a Client’s
investment objectives. PWM may consult with its Clients about the options and ramifications of transferring securities.
However, Clients are advised that when transferred securities are liquidated, they are subject to transaction fees,
fees assessed at the mutual fund level (i.e., contingent deferred sales charge), and/or tax ramifications.

The Advisor’s fee is exclusive of and in addition to any applicable securities transaction and custody fees and other
related costs and expenses described in Item 5.C. below, which may be incurred by the Client. However, the Advisor
shall not receive any portion of these commissions, fees, and costs.

Use of Independent Managers
As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio utilizing one or more
Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an
Independent Manager. The Advisor will only earn its Advisory fee as described above. The Advisor will allocate a
portion of the Advisory fee collected to the Independent Manager pursuant to the terms of the executed agreement
between the Advisor and the Independent Manager. The total blended fee, including the Advisor’s fee and the
Independent Manager’s fee, will not exceed 2.00% annually.

Financial Planning Services
PWM will typically include financial planning services in an overall wealth management engagement. For clients
who choose to contract for these services separately, the Advisor offers its services as a separate fixed project fee
ranging from $1,000 to $5,000. The Advisor’s fee is based on the complexity of the services to be provided and the
overall relationship with the Advisor. Fees may be negotiable at the sole discretion of the Advisor. An estimate for
total costs will be provided to the Client prior to engaging in these services.

Retirement Plan Advisory Services
Fees for retirement plan advisory services are charged an annual asset-based fee ranging from 0.30% to 1.00% and
are billed quarterly in advance, pursuant to the terms of the retirement plan advisory agreement. Retirement plan
fees are based on the market value of assets under management at the end of the prior quarter. Fees may be
negotiable depending on the size and complexity of the Plan.

                                             Palumbo Wealth Management, LLC
                                   1010 Northern Boulevard, Suite 310 Great Neck, NY 11021
                                         Phone: (516) 629-7073 | Fax: (516) 829-0731
Page 8                                             www.palumbowm.com

B. Fee Billing
Wealth Management Services / Investment Management Services
Advisory fees will be calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the
Custodian. The Advisor shall send an invoice to the Custodian indicating the fees to be deducted from the Client’s
...

Item 7 – Types of Clients

PWM provides investment advisory services to high-net-worth individuals, families, trusts, estates, businesses,
and retirement plans. These amounts may change over time and are updated at least annually by the Advisor.
PWM requires a minimum relationship size of $500,000, which may be reduced at the Advisor’s sole discretion.