Rubey & Rust Capital Management LLC

Item 5: Fees & Compensation

    Compensation for Our Advisory Services

    Comprehensive Portfolio Management*:

                   Assets Under Management               Annual Percentage of Assets Charge

                              $0 to $500,000                             1.00%

                       $500,001 - $1,000,000                             0.75%

                         $1,000,001 & Above                              0.50%

    *All fees are negotiable.

ADV Part 2A – Firm Brochure                          Page 5                        Rubey & Rust Capital Management, LLC

    Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Annualized
    fees are billed on a pro-rata basis quarterly in arrears based on the value of the account(s) on the last
    day of the quarter. Fees will be deducted from client account(s). In rare cases, our firm will agree to
    direct bill clients. As part of this process, Clients understand the following:
        a) The client’s independent custodian sends statements at least quarterly showing the market
            values for each security included in the Assets and all account disbursements, including the
            amount of the advisory fees paid to our firm;
        b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our
            firm will send an invoice directly to the custodian; and
        c) If our firm sends a copy of our invoice to the client, legend urging the comparison of
            information provided in our statement with those from the qualified custodian will be
            included.

    Retirement Plan Consulting:

    Our Retirement Plan Consulting services are billed a fee based on the percentage of Plan assets under
    management. The total estimated fee, as well as the ultimate fee charged, is based on the scope and
    complexity of our engagement with the client. Fees will not exceed 1.00% of Plan assets and are
    negotiable. The fee-paying arrangements for Retirement Plan Consulting service will be determined
    on a case-by-case basis and will be detailed in the signed consulting agreement. Clients will be
    invoiced directly for the fees.

    Other Types of Fees & Expenses

    Clients may incur transaction charges for trades executed in their accounts. These transaction fees
    are separate from our firm’s advisory fees and will be disclosed by the chosen custodian. Charles
    Schwab & Co., Inc. (“Schwab”) does not charge transaction fees for U.S. listed equities and exchange
    traded funds.

    Clients may also pay 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, initial or deferred sales
    charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and
    qualified retirement plan fees, and other fund expenses). Our firm does not receive a portion of these
    fees.

    Termination & Refunds

    Either party may terminate the advisory agreement signed with our firm for Comprehensive
    Portfolio Management services in writing at any time. Upon notice of termination pro-rata advisory
    fees for services rendered to the point of termination will be charged. If advisory fees cannot be
    deducted, our firm will send an invoice for due advisory fees to the client.

    Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing
    written notice to the other party. Full refunds will only be made in cases where cancellation occurs
    within five (5) business days of signing an agreement. After five (5) business days from initial signing,
    either party must provide the other party thirty (30) days written notice to terminate billing. Billing
    will terminate 30 days after receipt of termination notice. Clients will be charged on a pro-rata basis,
    which takes into account work completed by our firm on behalf of the client. Clients will incur charges
    for bona fide advisory services rendered up to the point of termination (determined as 30 days from
    receipt of said written notice) and such fees will be due and payable.

ADV Part 2A – Firm Brochure                        Page 6                         Rubey & Rust Capital Management, LLC

    Commissionable Securities Sales

    Our firm and representatives do not sell securities for a commission in advisory accounts.

Item 7: Types of Clients & Account Requirements

    Our firm has the following types of clients: Individuals and High Net Worth Individuals; Trusts,
    Estates or Charitable Organizations; Pension and Profit-Sharing Plans; and Corporations, Limited
    Liability Companies and/or Other Business Types.

    Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging
    us.