Ruggiero Investments Inc

Item 5: Fees and Compensation

A. Fee Schedule

Portfolio Management Services Fees

        Total Assets Under Management           Annual Fee

        All Assets                              Up to 2.50%

RI’s portfolio management fees are based on a percentage of assets under
management, including cash and money market positions. Our fee billing is
quarterly, in advance, and is calculated using the average daily balance of the
client’s account during the billing period.

To determine the average daily balance, we calculate the market value of the
account at the end of each business day during the billing period, add together
those daily values, and divide the total by the number of days in the period. The
applicable annual fee rate is then applied to this average balance.

This method of calculation is designed to be equitable, as it reflects the impact of
contributions, withdrawals, and market activity throughout the billing period,
rather than relying on the account value on a single day.

When an account engages during a month, it is prorated using the initial deposit.
These fees are negotiable and the final fee schedule is attached as Exhibit II of the
Investment Advisory Contract.

Financial Planning Fees

Fixed Fees

The rate for creating client financial plans is $50,000. The fees are negotiable and
the final fee schedule will be attached as Exhibit II of the Financial Planning
Agreement. Fees are paid in advance.

Hourly Fees

The hourly fee for these services is $2000. The fees are negotiable and the final
fee schedule will be attached as Exhibit II of the Financial Planning Agreement.
Fees are paid in advance.

Clients may terminate the agreement without penalty, for full refund of RI’s fees,
within five business days of signing the Financial Planning Agreement.
Thereafter, clients may terminate the Financial Planning Agreement with upon
written notice.

Pension Consulting Services Fees

AUM-based Fees for Pension Consulting

        Total Assets Under Management           Annual Fee

        $25,000 - $2,999,999                    2.50%

        $3,000,000 - $AUM max                   1.25%

RI offers different options regarding compensation for pension services being
rendered. For fees generated based on the assets under management, RI uses the
last day of the billing period of the just completed quarterly period for purposes of
determining the market value of the assets upon which the advisory fee is based.
These fees are negotiable, and the final fee schedule is attached as Exhibit II of the
Investment Advisory Contract. For additional Pension Consulting Services, RI
may receive compensation in the form of hourly charges or fixed fees at the
discretion of RI based on the service that is being rendered, the time to complete
the task, and the resources needed. These fees are negotiable.

Termination of Agreement

Clients may terminate the agreement without penalty for full refund of RI’s fees,
within five business days of signing the Investment Advisory Contract.
Thereafter, clients may terminate the Investment Advisory Contract with fifteen
days’ written notice.

B. Payment of Fees

Payment of AUM-based Portfolio Management Fees

AUM-based portfolio management fees are withdrawn directly from the client's
accounts with client's written authorization.

Payment of Financial Planning Fees

Fixed or Hourly Financial Planning fees are Invoiced and payable via credit card,
check, or wire. Fees are paid in advance.

Payment of AUM-based Pension Consulting Fees

AUM-based pension consulting fees are withdrawn directly from the client's
accounts with client's written authorization on a quarterly basis.

Payment of Estate Planning Fees

RI charges a project-based fee for Estate Planning Services offered through Estately
FreeWill. The fees start at $1,000 for an individual estate plan. The fee will be based
on the scope and complexity of the services provided by RI and Estately FreeWill.

C. Clients Are Responsible For Third Party Fees

Clients are responsible for the payment of all third-party fees (i.e. custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate
and distinct from the fees and expenses charged by RI. Please see Item 12 of this
brochure regarding broker/custodian.

D. Prepayment of Fees

RI’s fee billing is quarterly, in advance, and is calculated using the average daily
balance of the client’s account during the billing period.

This method of calculation is designed to be equitable, as it reflects the impact of
contributions, withdrawals, and market activity throughout the billing period,

       rather than relying on the account value on a single day.

       When an account engages during a month, it is prorated using the initial deposit.

       Clients may request to terminate their Investment Advisory Agreement with RI,
       by providing advance written notice. The Client shall be responsible for
       Investment Advisory Fees up to and including the effective date of termination.
       Upon termination, the Advisor will refund any unearned, prepaid Investment
       Advisory Fees from the effective date of termination to the end of the quarter, RI
       will return funds within 30 days.

       E. Outside Compensation For the Sale of Securities to Clients

       Neither RI nor its supervised persons accept any compensation for the sale of
       securities or other investment products, including asset-based sales charges or
       service fees from the sale of mutual funds that are managed within Ruggiero
       Investments Advisory.

Item 7: Types of Clients

RI generally provides advisory services to the following types of clients:

           ❖   Individuals
           ❖   High-Net-Worth Individuals
           ❖   Organizations
           ❖   Businesses
           ❖   Non-Profits
           ❖   Trusts
           ❖   Families

Minimum Account Size for Portfolio Management and Pension Consulting.

There is an account minimum of $25,000, which may be waived by RI in its discretion.