Rochester Investments Inc

Item 5 – Fees and Compensation

Rochester Investments charges fees for its investment advisory services that are based on a percentage
of the client’s total assets under management. Fees are negotiable and therefore may vary by client.
Rochester Investments considers cash to be an asset class, and will include it in the Assets Under
Management (AUM) fee calculation. The fee on cash & cash equivalent assets will exceed the money
market yield on cash assets. Individual accounts under $10,000 are charged an administration fee of
$25 per quarter. These fees are retained by the firm, and in the event the client terminates the
account within the quarter that the fee was charged, the fee is not refunded to the client(s).

Portfolio Management

The current (as of 1/1/2021) fee schedule for Investment Management Service is as follows:

                   Fee Schedule for Asset Management:
          Percentage       Assets under management

                   1.00%       of market value on the first $1,000,000
                   0.85%       of market value on the next $2,000,000
                   0.75%       of market value on the next $3,000,000
                   0.65%       of market value on the next $5,000,000
                   0.55%       of market value over $10,000,000

For the above management fee schedules, the fee is computed and charged quarterly in advance.
There is no minimum fee for portfolio management services.

For our Investment Management Services clients, Rochester Investments typically does not charge
an additional, or “extra” fee for financial planning services. Financial planning services are included
and provided within the annual investment management fee.

When financial planning services are not provided through our investment management services, we
will charge either an hourly fee or fixed fee. Rochester Investments charges an hourly financial
planning fees of $250 per hour. The hourly fee is billed to clients opting to pay per hour rather than
paying as a percentage of assets under management, or for any other services requested by the
clients.

For clients requesting financial plans, plan preparation is offered as follows:

               •    $2,500 for Silver Financial Plan
               •    $3,500 for Gold Financial Plan
               •    $4,500 for Platinum Financial Plan

For the portion of the clients' portfolio invested in registered investment companies, the client
generally pays two sets of fees. First, the client pays a standard quarterly fee on the market value of
total assets managed by Rochester Investments which can include assets in mutual funds.
Second, there is a management fee paid at the fund level which is deducted from the fund’s net asset
value. Likewise, other operating expenses are automatically deducted at the fund level.
Rochester Investments does not receive and will never receive any portion of the fee paid at the fund
level, but we monitor the expense ratios of the registered investment companies to determine their
size and appropriateness.

The client’s written agreement with Rochester Investments establishes the specific manner in
which fees are charged. Accounts initiated or terminated during a calendar quarter are charged a
prorated fee in the following quarter. Rochester Investments prorates fees for capital contributions
and withdrawals made during an applicable calendar quarter however these are adjusted on the
billing in the following quarter. Upon termination of any account, accepted with immediate notice,
Rochester Investments will refund any prepaid, unearned fees and collect any earned, unpaid fees,
except the $25 administration fees. Request for a full outbound transfer of assets to a different firm
will be considered a request for termination of the advisory relationship between Rochester
Investments and the client.

Rochester Investments’ fees are exclusive of brokerage commissions, transaction fees, and other
related costs and expenses which shall be incurred by the client. Clients may incur certain charges
imposed by custodians, brokers, third party investment and other third parties such as fees charged
by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire
transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions. Mutual funds and exchange traded funds also charge internal management fees, which
are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in
addition to Rochester Investments’ fee, and Rochester Investments does not receive any portion of
these commissions, fees, and costs.

Corporate Retirement Plan Consulting Fee

The management fees assessed for retirement plan consulting services vary based on the size of the
account and the consulting services requested. Rochester Investments’ annual fee can range from
.10% to 1.00% per year of the total plan assets under management or the annual fee can be a flat
charge fee. In some cases, Rochester Investments may also include an annual minimum fee based on
asset size and scope of service. Rochester Investments may also charge a flat charge fee in lieu
thereof on a per job basis.

                   Fee Schedule for Corporate Asset Management:
          Percentage       Assets under management

                1.00%         of market value on the first $1,000,000
                0.75%         of market value over $1M up to $3,000,000
                0.50%         of market value over $3M up to $5,000,000
                0.35%         of market value over $5M up to $10,000,000
                0.30%         of market value over $10M up to $15,000,000
                0.25%         of market value over $15M up to $50,000,000
                0.10%         of the market value over $50,000,000

Item 7 – Types of Clients

Rochester Investments provides portfolio management services to individuals, high net worth
individuals, retirement plans, corporations, trusts, estates, charitable institutions, municipal
government entities and private investment funds.

Rochester Investments requires a minimum account size of $500,000, however this requirement
can be waived at Rochester Investments’ discretion.