Richmond Brothers Inc

ITEM	5:	FEES	&	COMPENSATION

We	are	required	to	describe	our	brokerage,	custody,	and	fees	so	you	will	know	how	much	you	are	charged
and	by	whom	our	advisory	services	are	provided.

Comprehensive	Portfolio	Management

On	an	annualized	basis,	our	fees	for	continuous	portfolio	management	services	including	sub-advisor	fees
are	as	follows:

Assets	under	Management							 	Annual	Percentage	Charge:
$0	-	$500,000	 	            	       	        	       1.75%
$500,	000.01	-	$1,000,000	          	        	       1.55%
$1,000,000.01	-	$5,000,000	 	                	       1.15%
The	annual	percentage	for	household	assets	greater	than	$5,000,000	is	a	non-tiered	1.00%

Fees	are	calculated	by	dividing	the	annual	advisory	fee	percentage	by	365	(the	number	of	days	in	a	year)
and	multiplying	that	by	the	average	daily	balance	of	the	previous	month	and	the	number	of	invested	days
in	the	billing	month.	This	is	calculation	is	performed	for	each	tier	in	which	Client’s	assets	fall.

Fees	are	calculated	on	account	balances	(including	cash	and	cash	equivalents)	by	household	and	applied
to	the	tiered	fee	schedule	above.	They	are	typically	not	negotiable	and	offer	discounts	to	employees	and
family	members	accounts.	The	initial	billing	will	be	performed	during	the	next	monthly	billing	cycle	after
account	 opening	 and	 include	 fees	 for	 services	 rendered.	 Fees	 will	 be	 deducted	 from	 each	 managed
account	monthly	in	arrears.	Please	refer	to	the	Addendum(s)	to	your	advisory	agreement	or	separate
Sub-Advisor	agreement(s),	if	any,	for	additional	information	about	fees.	As	part	of	this	process,	Client	is
made	aware	and	agrees	to	of	the	following:
     a)	 Client’s	independent	custodian	sends	statements	at	least	quarterly	showing	all	disbursements
          for	Client’s	account,	including	the	amount	of	the	advisory	fees	paid	to	Adviser.
     b)	 This	Agreement	provides	Client’s	authorization	permitting	advisory	service	fees	to	be	deducted
          directly	from	Client’s	managed	account(s).
     c)	 If	Adviser	sends	a	copy	of	its	invoice	to	Client,	it	will	include	a	legend	urging	Client	to	compare
          information	provided	in	our	statement	with	that	provided	by	the	qualified	custodian.

Fees	 will	 be	 deducted	 from	 each	 managed	 account.	 Beginning	 in	 2026,	 this	 will	 be	 performed	 by	 an
outside	billing	service.	As	part	of	this	process,	the	client	is	made	aware	of	the	following:
     a)	 Your	 independent	 custodian	 sends	 statements	 at	 least	 quarterly	 to	 you	 showing	 all
          disbursements	for	your	account,	including	the	amount	of	the	advisory	fees	paid	to	us.
     b)	 A	 fully	 executed	 advisory	 agreement	 provides	 your	 authorization	 permitting	 advisory	 service
          fees	to	be	deducted	directly	from	your	managed	account(s).
     c)	 If	we	send	a	copy	of	our	invoice	to	you,	it	will	include	a	legend	urging	you	to	compare	information
          provided	in	our	statement	with	that	provided	by	the	qualified	custodian.

Financial	Planning	&	Consulting

We	charge	on	an	hourly	or	flat	fee	basis	for	financial	planning	and	consulting	services.	The	total	estimated
fee,	 as	 well	 as	 the	 ultimate	 fee	 that	 we	 charge	 you,	 is	 based	 on	 the	 scope	 and	 complexity	 of	 our
engagement	 with	 you.	 Our	 hourly	 fees	 are	 $250	 to	 $300	 for	 financial	 advisors,	 and	 $50	 to	 $75	 for
administrative	time.	Flat	fees	generally	range	from	$1,000	to	$2,000.

The	fee(s)	for	our	Financial	Planning	and	Consulting	service	shall	be	directly	billed	to	you	and	due	to	us
within	30	days	of	your	financial	plan	or	consulting	being	delivered	or	consultation	rendered	to	you.	In	all
cases,	 we	 will	 not	 require	 a	 retainer	 exceeding	 $1,200	 when	 services	 cannot	 be	 rendered	 within	 six
months.

Medicare	Consulting	Services
Medicare	consulting	services	are	performed	with	the	assistance	of	Advisors	Excel	Medicare	Solutions
Team.	We	receive	fifty	percent	of	the	commissions	earned	through	insurance	products	sold	to	you	by
Advisors	 Excel.	 You	 do	 not	 pay	 these	 fees	 but	 rather	 the	 commissions	 are	 paid	 by	 the	 insurance
companies	if	you	become	a	policyholder.	There	is	a	conflict	of	interest	because	commissions	are	only
collected	when	enrolled	in	Medicare	Advantage	as	opposed	to	enrollment	in	traditional	Medicare.	We	are
incentivized	 to	 recommend	 these	 products	 which	 generate	 fees.	 To	 mitigate	 this	 conflict,	 a	 thorough
discussion	of	both	traditional	Medicare	and	Medicare	Advantage	benefits	and	costs	are	an	integral	part
of	our	Medicare	Consulting	Services.	No	client	is	under	any	obligation	to	purchase	insurance	products
through	 Advisors	 Excel	 at	 any	 time.	 Our	 goal	 is	 to	 plainly,	 completely	 and	 accurately	 explain	 all	 your
options	and	help	you	find	the	best	course	that	is	in	your	best	interest.

Other	Types	of	Fees	and	Expenses

Our	clients	will	incur	transaction	charges	for	trades	executed	in	their	accounts.	These	transaction	fees
are	separate	from	our	fees	and	will	be	disclosed	by	the	firm	that	the	trades	are	executed	through.	Also,
clients	will	pay	the	following	separately	incurred	expenses,	which	we	do	not	receive	any	part	of:	charges
imposed	directly	by	a	mutual	fund,	index	fund,	or	exchange	traded	fund	which	shall	be	disclosed	in	the
fund’s	prospectus	(i.e.,	fund	management	fees	and	other	fund	expenses).

Adviser	shall	never	have	custody	except	for	authorized	fee	withdrawal	of	any	Client	funds	or	securities
for	 Comprehensive	 Portfolio	 Management	 services,	 as	 the	 services	 of	 a	 qualified	 and	 independent
custodian	will	be	used.	The	fees	charged	are	calculated	as	described	above	and	are	not	charged	on	the
basis	of	a	share	of	capital	gains	upon,	or	capital	appreciation	of,	the	funds,	or	any	portion	of	the	funds	of
an	advisory	client	(15	U.S.C.	§80b-5(a)(1)).

Termination	and	Refunds

We	charge	our	advisory	fees	quarterly	in	advance.	In	the	event	that	you	wish	to	terminate	our	services,
...

ITEM	7:	TYPES	OF	CLIENTS	&	ACCOUNT	REQUIREMENTS

We	 provide	 services	 different	 types	 of	 clients	 including	 Individuals	 and	 High	 Net	 Worth	 Individuals,
Charitable	Organizations,	Pension	and	Profit	Sharing	Plans,	Corporations,	Limited	Liability	Companies
and/or	Other	Business	Types.

We	 require	 a	 minimum	 account	 balance	 of	 $250,000	 for	 our	 Comprehensive	 Portfolio	 Management
service.	If	not	negotiated	otherwise,	this	minimum	account	balance	requirement	is	required	throughout
the	course	of	the	client’s	relationship	with	our	firm.