Schaffer & Company Asset Management Inc

Item 5   Fees and Compensation

A. Fee Schedule

Portfolio management fees are generally payable monthly in arrears and are based on the
following annual fee schedule:

Managed combined accounts under $50,000, $85 per month
1.85% per annum on assets under management from $50,001 to $100,000
1.75% per annum on assets under management from $100,001 to $250,000
1.30% per annum on assets under management from $250,001 to $500,000
1.10% per annum on assets under management from $500,001 to $1,000,000
1.00% per annum on assets under management from $1,000,001 to $4,999,000
0.80% per annum on assets under management over $5,000,000

Hourly fees for any services outside of portfolio management services (specifically managing of
assets, trading and/or monitoring) if under a fee schedule or fixed fee will be billed at $330 per
hour. This may be general consultation, financial planning or parts of financial planning, tax
planning, estate, or trust planning, etc.

The foregoing represents the fees the firm generally charges. However, fees are variable based
on portfolio construction in certain circumstances and arrangements with any particular client
may differ from those described above based on level of service provided. Fees are always
established in writing prior to services rendered.

The portfolio management agreement may not be modified or amended except in writing and
signed by both SCHAFFER and the Client. SCHAFFER or the Client may terminate the
agreement within five days of the date of acceptance without penalty to the Client. After the
five-day period, agreement can terminate upon 30 days written notice from the Client; or (2) five
business days after mailing by SCHAFFER of notice of termination to the Client; or (3) at such
time as otherwise mutually agreed upon in writing by SCHAFFER and the Client.

B. Billing Method

Fees are payable at the end of each month, computed on the value of the account using the last
known balance of the account on the last day of the month. The fee is prorated for a partial
month based on the number of days in the month.

Fees shall be deducted from clients' account unless client chooses to pay from another source.
Fees are shown on month end statements for CHARLES SCHWAB clients as "MGMTFEE TO
ADVISOR" in the transaction detail – fees & charges section. Invoices are mailed out at the
beginning of the month for pension clients who do not have accounts with CHARLES SCHWAB.

Form ADV: Part 2A                                                                          Page 8
Date: 03/31/2026
CRD #138463
SEC File Number 801-92168

Client will notify SCHAFFER in writing prior to agreement execution. Detailed billing statements
are produced and available upon request at any time.

C. Other Types of Fees or Expenses

In addition to portfolio management fees listed above, additional services such as
comprehensive financial planning, tax planning, estate planning, 529 plans, general consultation
outside of investment advisory services related to portfolio management, etc. shall be billed at
$330 per hour or fixed fees.

D. Advance Payments

SCHAFFER does not normally accept advance payments but will refund for portion of fees paid
in advance as agreed between SCHAFFER and the client(s) upon termination of agreement.

E. Compensation

The fee charged is calculated as described above and is not charged on the basis of a share of
capital gains upon or capital appreciation of the funds or any portion of the funds of an advisory
Client (SEC Rule 205(a)(1)).

1. SCHAFFER does not participate in compensation to supervised persons for the sale of
securities or other investment products, including asset-based sales charges or service fees
from the sale of mutual funds.

2. SCHAFFER has not entered into agreements with various third-party investment advisers.
Schaffer directly provides investment supervisory services on all assets.

3. Principals and associated persons of SCHAFFER will sell insurance products and will
receive compensation on the sale of such products from the insurance companies directly.

4. While SCHAFFER endeavors at all times to put the interest of the Clients first as part of
SCHAFFER'S fiduciary duty, Clients should be aware that the receipt of additional
compensation itself creates a potential conflict of interest.

Although SCHAFFER believes its advisory fees are competitive, lower fees for comparable
services may be obtained from other sources.

Depending on certain circumstances, SCHAFFER may require a minimum fee for financial
planning clients. This will be discussed and agreed upon prior to entering into a contract with
any client.

The foregoing represents the fees the firm generally charges. However, fees are negotiable in
certain circumstances and arrangements with any particular client may differ from those
described above based on level of service provided.

The portfolio management agreement may not be modified or amended except in writing and
signed by both SCHAFFER and the Client. SCHAFFER or the Client may terminate the
agreement within five days of the date of acceptance without penalty to the Client. After the

Form ADV: Part 2A                                                                         Page 9
Date: 03/31/2026
CRD #138463
SEC File Number 801-92168

five-day period, agreement can terminate upon 30 days written notice from the Client; or (2) five
business days after mailing by SCHAFFER of notice of termination to the Client; or (3) at such
time as otherwise mutually agreed upon in writing by SCHAFFER and the Client.

Item 7    Types of Clients

SCHAFFER provides investment advice to individuals, trusts, estates, charitable organizations,
pensions and profit-sharing plans, corporations and business entities.

Depending on certain circumstances, SCHAFFER may require a minimum fee for financial
planning clients. This will be discussed and agreed upon prior to entering into a contract with
any client.

Should a client choose to implement the recommendations contained in the financial plan,
SCHAFFER suggests the client work closely with his/her IAR, attorney, accountant, insurance
agent, and/or stockbroker. Implementation of the financial plan is entirely at the client's
discretion.

The financial planning agreement may not be modified or amended except in writing and signed
by both the SCHAFFER and the Client. SCHAFFER and the Client may terminate the

Form ADV: Part 2A                                                                              Page 11
Date: 03/31/2026
CRD #138463
SEC File Number 801-92168

agreement within five days of the date of acceptance with no penalty to the Client. After the
five-day period, agreement can terminate upon 30 days written notice from the Client; or (2) five
business days after mailing by SCHAFFER of notice of termination to the Client; or (3) at such
time as otherwise mutually agreed upon in writing by SCHAFFER and the Client. SCHAFFER
will return to the Client any unused portion of the prepaid financial planning fees.

In addition to the aforementioned services, SCHAFFER provides advice on non-securities
matters. Generally, this in connection with the rendering of estate planning, insurance, and/or
annuity advice.