Rochester Wealth Strategies LLC

Item 5. Fees and Compensation
      Rochester Wealth Strategies offers services on a fee basis, specifically, fees based upon assets under
      management.

      Wealth Management Fees

      Rochester Wealth Strategies offers investment management services for an annual fee based on the amount
      of assets held in accounts under the Firm’s management. This management fee varies in accordance with
      the following fee schedule:

                             Portfolio Value                     Annual Fee
                          $0.00 - $500,000                       1.50%
                        $500,000 - $1,000,000                    1.25%
                       $1,000,000 - $5,000,000                   1.00%
                      $5,000,000 - $10,000,000                   0.75%
                         $10,000,000 & Over                      0.50%

      The annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets in
      accounts being managed by Rochester Wealth Strategies on the last day of the previous billing period. If
      assets in excess of $25,000 are deposited into or withdrawn from an account after the inception of a billing
      period, the fee payable with respect to such assets is adjusted to reflect the interim change in portfolio value.
      For the initial period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory
      agreement is terminated, the fee for the final billing period is prorated through the effective date of the
      termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as
      appropriate.

      In circumstances where clients of the Firm hold legacy or client-direct positions within accounts designated
      to the Firm’s management, the Firm will not manage such assets on an on-going basis. Nonetheless, the
      market value of such individual equity securities within client accounts will be included in the total market
      value of the assets in accounts being managed by the Firm.

      For certain clients, Rochester Wealth Strategies charges an advisory fee for services provided to the Held
      Away Accounts discussed in Item 4. This fee is deducted from an account under Rochester Wealth
      Strategies’ management or paid directly by the client on a quarterly basis. Fees are typically based on the
      assets within these Held Away Accounts and are charged according to the valuation of the accounts at the
      close of the quarter as valued by the account custodian. Fees will typically be based on the client’s full

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 Disclosure Brochure

      portfolio value, including the Held Away Accounts. Please note that the billing cycle explained above that
      describes the billing process related to deposits or withdrawals in excess of $25,000 (known as “flow
      billing”) will also be performed for advisory fees for Held Away Accounts. The specific fee schedule
      charged by Rochester Wealth Strategies is established in Exhibit A to the client’s Wealth Management
      Agreement with Rochester Wealth Strategies. The client acknowledges that for the Held Away Accounts,
      the current account management system utilized by Rochester Wealth Strategies is provided by Pontera
      (formerly FeeX). Pontera shall have trading authority on the Held Away Accounts and will retain a portion
      of the wealth management fee collected by Rochester Wealth Strategies.

      Pension Consulting Fees
      Each pension consulting engagement is individually negotiated and tailored to accommodate the needs of
      the individual pension fund trustee, as memorialized in the Agreement. Rochester Wealth Strategies charges
      an annual asset-based fee for its pension consulting services, depending upon the amount of assets to be
      managed. These fees vary, based on the scope of the services to be rendered.

      Donor Advised Funds Fees

      In addition to the Firm's advisory fee, Schwab Charitable assesses administrative fees on Donor Advised
      Fund accounts (currently 0.10% - 0.60% annually). These fees are charged by Schwab Charitable and are
      separate from any advisory fees charged by the Firm. The administrative fee is generally the same regardless
      of whether the account is managed by an external investment advisor. For accounts invested in Schwab
      Charitable's core investment pools, the administrative fee may be reflected within the investment option's
      net performance. For advisor-managed accounts, the administrative fee is typically disclosed as a separate
      quarterly charge on account statements

      Fee Discretion

      At our discretion, Rochester Wealth Strategies may combine the account values of family members, such
      as children, parents, and other types of related accounts, to determine the applicable advisory fee.
      Combining account values may increase the asset total, which may result in your paying a reduced advisory
      fee based on the available breakpoints in our fee schedule stated above. Rochester Wealth Strategies may
      also reduce advisory fees paid by some clients based on certain criteria, including, but not limited to, family
      relationships and Held Away accounts that retain a portion of the wealth management fee collected by
      Rochester Wealth Strategies.

      Additional Fees and Expenses

      In addition to the advisory fees paid to Rochester Wealth Strategies, clients also incur certain charges
      imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other
      financial institutions (collectively “Financial Institutions”). These additional charges include securities

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 Disclosure Brochure

      brokerage commissions, transaction fees, custodial fees, fees attributable to alternative assets, reporting
...

Item 7. Types of Clients
      Rochester Wealth Strategies offers services to individuals, pension and profit-sharing plans, trusts, estates,
      charitable organizations, corporations and business entities.

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 Disclosure Brochure

      Minimum Account Value

      As a condition for starting and maintaining an investment management relationship, Rochester Wealth
      Strategies imposes a minimum portfolio value of $500,000. Rochester Wealth Strategies may, in its sole
      discretion, accept clients with smaller portfolios based upon certain criteria, including anticipated future
      earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related
      accounts, account composition, pre-existing client, account retention, and pro bono activities. Rochester
      Wealth Strategies only accepts clients with less than the minimum portfolio size if the Firm determines the
      smaller portfolio size will not cause a substantial increase of investment risk beyond the client’s identified
      risk tolerance. Rochester Wealth Strategies may aggregate the portfolios of family members to meet the
      minimum portfolio size.