ITEM 5 - FEES AND COMPENSATION
RAM earns an investment management fee (“Management Fee”) in its Private Access Program and
Third-Party Money Manager Services. The Management Fees are an annual fee based upon a
percentage of the market value of assets managed or overseen by the Firm. Fees are range from 0.25%
to 1%, depending on the investment strategy, account size and other factors. Fees are calculated using
the weighted average net assets (securities, cash, and cash equivalents) under management (“Net
Assets”) of each client’s account for the prior quarter. Management Fees are payable in advance as of
the first business day of each quarter by debiting the client’s account (provided debiting is authorized in
writing by the client), on a date not later than the tenth (10th) business day after the client’s receipt of a
correct invoice for such management fees.
The Firm’s fee may, depending on negotiated terms with the client, be exclusive of or inclusive of
brokerage commissions, transaction fees and other related costs and expenses which may be incurred
by the client or the Firm.
Sub-Advisory Accounts
RAM also provides investment sub-advisory services to unaffiliated investment advisors for investment
strategies, wrap programs, and other accounts. The sub-advisory fees that RAM receives for these
services are negotiated between the Firm and the principal advisor for each sub-advised strategy or
account. RAM sends an invoice to the unaffiliated investment advisor on a date not later than the tenth
(10th) business day of the month.
Refund Policy
RAM’s advisory services may be terminated (1) at any time by either party hereto after giving the other
party at least five (5) business days prior written notice of such termination; or (2) by the client, without
penalty, upon written notice within five (5) business days after entering into the Agreement. Any fees
paid in advance will be prorated to the date of termination specified in the notice of termination and
any unearned portion thereof will be refunded to the client.
Other Fees and Expenses
There may be additional fees or charges that result from the maintenance of or trading within your
account. These fees are imposed by third parties in connection with investments made through client
accounts, including but not limited to, brokerage commissions, no-load mutual fund 12(b)-1 distribution
fees, certain deferred sales charges on previously purchased mutual funds, IRA and Qualified Retirement
Plan fees, and also acquired fund fees and expenses.
Other Compensation
On a case by case basis, RAM is paid a fixed fee or retainer fee for certain investment related research
and advice and/or investment operations work. These fees are determined based on the scope of work
or project. In addition, RAM may enter into arrangements to provide model information or
purchase/sale recommendations for models and other portfolios. In such an arrangement, RAM will
provide recommended portfolio transactions based on pre-established criteria, and the client will make
the investment decisions and execute the transactions. These will be deemed assets under advisement,
and RAM will charge a Management Fee negotiated with the client.
Other Compensation of Supervised Persons
Michael Guy Epstein is licensed as a registered representative to sell securities through Mid-Continent
Securities Advisors, Ltd., a registered broker/dealer, member FINRA/SPIC. In this capacity, Mr. Epstein
will receive commission-based compensation in connection with the with the purchase and sales of
securities.
Compensation earned by Mr. Epstein in his capacity as a registered representative is separate and in
addition to advisory fees RAM charges. This practice presents a conflict of interest because Mr. Epstein
has an incentive to effect securities transactions to clients for the purpose of generating commissions
rather than solely based on client needs. Clients are under no obligation, contractually or otherwise to
purchase these securities through Mr. Epstein. He devotes approximately 60% of his time per week
working as a registered representative.