Roble Belko and Company Inc

Fees and Compensation

Wealth Management:

Listed below is a schedule of Roble’s management fees. In some circumstances, such as
those involving assets over $25 million, fees will be negotiable. These services may
include nonrecurring advice such as hedging and asset allocation. Roble’s management

 fees are exclusive of other fees particular to a client’s individual holdings (e.g. mutual
 fund fees).

           Account Assets                Annual Rate

          $3.0 to $10 Million               0.75%

           Next $15 Million                 0.60%

           Over $25 Million           *Fees negotiable*

Generally, Roble’s minimum account size is $3 million, but Roble may use its discretion
to accept lesser amounts. Roble often also aggregates related accounts for purposes of
meeting this minimum as well as for reaching breakpoints in the fee schedule. For
accounts having less than $3 million, fees will be negotiated between Roble and the client,
subject to a minimum fee ranging from $5k to $20k. Minimum fees are based on several
factors which may include but are not limited to, nature and complexity of the prospective
client and potential for future business.

 The frequency of these fee payments will be quarterly and payable in arrears, based on
 the month-end market value of the subject quarterly billing period. Typically, these fees
 are deducted from the client’s investment account. In some cases, the client prefers to be
 billed directly and if so, Roble will take direct payment instead.

 Other Advisory Services:

 Roble provides other advisory services on a limited basis to clients at either an asset-
 based fee or a fixed annual fee, generally ranging from $5k to $200k depending on the
 nature and complexity of each client’s circumstances and upon mutual agreement with
 the client. These fees may be negotiable under certain circumstances. The frequency of
 these fee payments will be quarterly and payable in arrears, based on the month end
 notional value of the subject quarterly billing period, or based on some predetermined
 fixed fee.

Sub-Advisory Services:

There will be additional fees associated with any sub-advisor services. There will be a
separate Agreement that you will sign with the sub-advisor that will lay out their fee
structure which you will be responsible for paying. Please see their ADV Part 2A and
advisory agreement to review the sub-advisor’s fees, calculations, and methodology.
Brokerage fees and/or transaction ticket charges associated with managing the sub-advisor
account and charged by the custodian will be passed directly to each client’s account. Roble
does not receive any portion of such commissions or fees from the custodian or sub-
advisor. Management fees charged by Roble are separate and distinct from those set by the
sub-advisor. Roble and the sub-advisor do not share any fees.

General Information:

Fees and account minimums are negotiable at Roble’s discretion.

A client has the right to terminate its Investment Advisory Agreement with Roble without
penalty within five business days after entering into the agreement. Thereafter, generally,
the Investment Advisory Agreement may be canceled at any time, by either party, for any
reason upon receipt of written notice (or as otherwise specified in the agreement). In the
event that advisory services are provided for less than a full calendar quarter, fees will be
calculated on a pro rata basis for that quarter.

As with other investment accounts, clients will incur fees and expenses, other than our
investment advisory fees, when we manage a client’s assets. Clients will incur brokerage
costs, other transaction costs and other related costs and expenses such as brokerage
commissions, mark-ups, mark-downs and other amounts included in the price of a
security, custodian fees, administrative fees, interest charges, odd-lot differentials,
transfer taxes, wire transfer fees, and exchange and SEC fees. Additionally, when Roble
invests a client account in mutual funds, in addition to Roble’s advisory fee, the client’s
account will incur the ordinary fees and expenses charged by mutual funds to their
shareholders. These fees and expenses are described in each fund's prospectus, and will
generally include a management fee and transfer agent fees and may include distribution
fees, shareholder servicing fees, mailing and printing expenses, recordkeeping
fees,networking fees and other fees and expenses. If the fund also imposes sales charges,
a client may pay an initial or deferred sales charge. A client could invest in a mutual fund
directly, without the services of Roble. In that case, the client would not receive the
services provided by Roble which are designed, among other things, to assist the client in
determining which mutual fund or funds are most appropriate to each client's financial
condition and objectives. Accordingly, the client should review both the fees charged by
the funds and the fees charged by Roble to fully understand the total amount of fees to be
paid by the client and to thereby evaluate the advisory services being provided.

Roble and its supervised persons do not accept compensation for the sale of securities or
other investment products, nor do they accept asset-based sales charges or service fees
from the sale of mutual funds.

Please refer to “Brokerage Practices” in this brochure for a discussion of Roble’s
brokerage practices, including factors that we consider when selecting brokers and
dealers for client transactions.

               Performance-Based Fees and Side-By-Side Management

Roble does not charge any performance-based fees (i.e. fees based on a share of capital
gains or capital appreciation of the assets of a client).

Types of Clients

Roble provides advisory services to various types of clients, such as individuals, trusts,
corporations, pension/profit sharing plans, and charitable organizations. Generally,
Roble’s minimum account size is $3 million, but Roble may use its discretion to accept
lesser amounts. Roble often also aggregates related accounts for purposes of meeting this
minimum as well as for reaching breakpoints in the fee schedule.

             Methods of Analysis, Investment Strategies and Risk of Loss

Roble takes an approach to investing that is tailored to each client’s unique set of
circumstances. For each client, the firm uses a multi-step process to construct and
maintain investment portfolios.

Asset Allocation:

When onboarding a new client, we discuss with the client the client’s investment
objectives, risk tolerance, cash flow needs, and current tax situation. This discussion
informs our preparation of an appropriate investment plan for the client. With a focus on
the client’s long-term objectives, we select strategic asset class ranges, as described
below. Though an investment strategy is ultimately tailored to each client’s particular
circumstances, the range of strategic asset allocation strategies generally falls into three
categories: capital preservation, balanced and growth, all as described below.

       Capital Preservation Allocation Strategy

       This strategy is for clients who are at the stage of their lives where they are reliant
       on portfolio income, and therefore the asset allocation strategy is driven by the
       client’s cash flow and liquidity needs. As a result, fixed income assets will make
       up the largest part of the asset allocation, generally between 40% and 70% of the
       portfolio when including cash. The equity allocation will be far less, generally in
       the range of 20% to 40%, while alternative assets make up the remainder of the
       asset allocation at 5% to 25% of the portfolio.

       Balanced Allocation Strategy

       This strategy is for clients who are not reliant on income from the portfolio, as
       they have a longer time horizon and/or they are still earning income to cover their
       living expenses. As such, the equity allocation is greater than above, generally in
       the range of 40% to 60%. Given the modest risk tolerance of these clients, the
       fixed income allocation is still relatively significant in the 20% to 50% range,
       while alternative assets make up the remainder of the asset allocation at 5% to
       25% of the portfolio.

       Growth Allocation Strategy

       This strategy is for clients who typically have a significantly longer time horizon
       and/or a much higher risk tolerance than others. As such, the equity allocation is

       even larger than the strategies detailed above, generally in the range of 50% to
       70%. Given the much higher risk tolerance of these clients, the fixed income
       allocation is not as significant in the 15% to 35% range, while alternative assets
       make up the remainder of the asset allocation at 5% to 25% of the portfolio.

While our clients’ strategies typically fall into one of the three asset allocation categories
set forth above, some client circumstances dictate an investment strategy outside of the
range of strategies mentioned above.

Once we have selected an asset allocation strategy that is appropriate for a client’s
circumstances, investment guidelines and benchmarks are then established with target
ranges for the three major asset categories (equity, fixed income and alternative assets).
Benchmarks are created using the approximate midpoint of the asset class ranges, using
industry accepted market indices. Once the guidelines are agreed upon, Roble will
analyze the existing legacy portfolio and determine the best approach to transition to the
new asset mix and investment targets.

As noted above, Roble will construct an account using three asset categories –equity,
fixed income, and alternative assets – in proportions appropriate for the selected
allocation strategy. The following provides additional details on the types of investments
Roble may select for an account in each of the three asset categories.

       Equity Investments

       Equity investments may include common stock, options, and limited partnerships.

       Fixed Income Investments

       Fixed income investments may include taxable securities (e.g. treasuries,
       agencies, corporates, and asset backeds), convertible securities, and tax-
       advantage securities (e.g. municipal bonds and preferred stock).

       Alternative Asset Investments

       Alternative assets are non-traditional investments in which their long run returns
       are not expected to be highly correlated with the traditional stock and bond
       markets. Investments in this category may include common stock, debt
       instruments, limited partnerships, direct investments with specialty investment
       managers, hedge funds, fund of funds, private equity, oil/gas and natural
       resources, REITS, gold, precious metals and other commodities.

Note that in addition to making direct investments, Roble often invests in mutual funds,
exchange-traded funds and closed-end funds that themselves invest in equity, fixed
income or alternative assets, in order to gain exposure to any of the three asset categories.
Further, to the extent consistent with a client’s investment strategy, Roble often keeps a
portion of a client account invested in “cash” (money market mutual funds, commingled
funds, and/or money market securities).

Occasionally, Roble uses hedging instruments and strategies to reduce risk or to facilitate
tax management. These hedging strategies may use option contracts (puts and calls) or
the short selling of individual securities.

Though wealth management and top-down asset allocation are the predominant part of
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