Saperston Legacy Advisors Inc

Item 5     Fees and Compensation

                        INVESTMENT SUPERVISORY SERVICES ("ISS")
                         INDIVIDUAL PORTFOLIO MANAGEMENT FEES

Advisory Fees: the maximum annual fee on the programs is 2% of assets under management, based
upon the market value of assets accepted for management on the date of such acceptance and
thereafter using the portfolio value on the last business day of the preceding quarter. This is true
whether the fees are billed in arrears or advance.
Our advisory fees are negotiable and can be varied for certain clients in our sole
discretion. Lower fees for comparable services could be available from other sources.
In the event fees are billed in advance and the client relationship is terminated prior to the end of a
billing period, the unearned portion of the fee, calculated by means of a daily rate, is returned to the
client.

Limited Negotiability of Advisory Fees: Although Saperston Legacy Advisors, Inc. has established
the aforementioned maximum fee, we retain the discretion to waive or negotiate fees on a client-by-
client basis, not to exceed our 2% maximum fee. Client facts, circumstances and needs are
considered in determining the fee. These include the complexity of the client, assets to be placed
under management, anticipated future additional assets; related accounts; portfolio style, account
composition, reports, among other factors. The specific annual fee is identified in the contract between
the adviser and each client.
Discounts, not generally available to our advisory clients, may be offered to family members and
friends of associated persons of our firm.
Additions and Withdrawals: Client may make additions or withdrawals within their account at any
time. Additional assets received, into an account, after it is opened shall be charged a pro-rata fee
based upon the number of days remaining in the quarter. This applies only to accounts which are
billed quarterly in advance. Client may withdraw account assets upon notice to the Adviser, subject to
the usual and customary securities settlement procedures. No fee adjustments shall be made for
account appreciation or depreciation within a billing period (quarterly). A pro rata refund of fees
charged shall be made if the account is closed within a billing period. Adviser shall impose no start
up, closing or penalty fees in connection with the account. SLAI retains the right to make a fee
adjustment for withdrawals from an account on a case-by-case basis.
Management personnel and other related persons of our firm are licensed as insurance agents or
brokers. In their separate capacities, these individuals are able to implement investment
recommendations for advisory clients for separate and typical compensation (i.e., commission or other
sales-related forms of compensation). This presents a conflict of interest to the extent that these
individuals recommend that a client invest in a product which results in a commission being paid to the
individuals. The implementation of any or all recommendations is solely at the discretion of the client.

                                    GENERAL INFORMATION
Termination of the Advisory Relationship: A client agreement may be canceled at any time, by
either party, for any reason upon receipt of 30 days written notice. As disclosed above, certain fees
are paid in advance of services provided. Upon termination of any account, any prepaid, unearned
fees will be refunded. In calculating a client’s reimbursement of fees, we will pro rate the
reimbursement according to the number of days remaining in the billing period.
In the event of termination of the agreement in any manner, SLAI will have no independent obligation
to recommend or take any action with regard to the securities, cash or other investments in the
account and SLAI will be under no obligation to liquidate securities owned by client.
Mutual Fund Fees: All fees paid to Saperston Legacy Advisors, Inc. for investment advisory services
are separate and distinct from the fees and expenses charged by mutual funds and/or ETFs to their
shareholders. These fees and expenses are described in each fund's prospectus. These fees will
generally include a management fee, other fund expenses, and a possible distribution fee. 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 our services. In that case, the client would not receive the services
provided by our firm 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 our fees to fully
understand the total amount of fees to be paid by the client and to thereby evaluate the advisory
services being provided.
Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the
fees and expenses charged by custodians and imposed by broker dealers, including, but not limited
to, any transaction charges imposed by a broker dealer with which an independent investment
manager effects transactions for the client's account(s). Please refer to the "Brokerage Practices"
section (Item 12) of this Form ADV for additional information.
Grandfathering of Minimum Account Requirements: Pre-existing advisory clients may have been
subject to Saperston Legacy Advisors, Inc.'s minimum account requirements and advisory fees in
effect at the time the client entered into the advisory relationship. Therefore, our firm's minimum
account requirements may differ among clients.
ERISA Accounts: Saperston Legacy Advisors, Inc. is deemed to be a fiduciary to advisory clients that
are employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee
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Item 7     Types of Clients
Saperston Legacy Advisors, Inc. provides advisory services to the following types of clients:
 Individuals (other than high net worth individuals)
 High net worth individuals
 Pension and profit-sharing plans (other than plan participants)
 Charitable organizations
 Corporations or other businesses not listed above