Searle & Co

Item 5 Fees and Compensation
Please refer to the "Advisory Business" section above Item 4 in this brochure for information on our
advisory fees, fee deduction arrangements, and refund policy according to each service we offer.

Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in
mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds or exchange
traded funds (described in each fund's prospectus) to their shareholders. These fees will generally
include a management fee and other fund expenses. You will also incur transaction charges and/or
brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by
the broker-dealer or custodian through whom your account transactions are executed. To fully
understand the total cost you will incur, you should review all the fees charged by mutual funds,
exchange traded funds, our firm, and others. For information on our brokerage practices, please refer
to the "Brokerage Practices" section of this brochure.

Compensation for the Sale of Securities or Other Investment Products
Our firm is also a securities broker-dealer and a member of the Financial Industry Regulatory Authority
(FINRA), and the Securities Investor Protection Corporation (SIPC) and certain persons associated
with our firm who provide investment advice are also licensed as registered representatives. We will
receive commission-based compensation in connection with the purchase and sale of securities,
including 12b-1 fees for the sale of investment company products. Compensation earned by our firm
and registered representatives is separate and in addition to our advisory fees. This practice presents
a conflict of interest because persons providing investment advice on behalf of our firm who are
registered representatives have an incentive to effect securities transactions for the purpose of
generating commissions rather than solely based on your needs.

We also derive income from commission-based compensation from the sale of investment products we
recommend to our non-advisory clients. However, some advisory clients will also pay commissions for
investment products sold through our company.

We typically receive commissions on advisory accounts for non-qualified clients. When appropriate for
advisory accounts, we will recommend the purchase of no-load mutual funds. However, you are under
no obligation, contractually or otherwise, to purchase securities products through any person affiliated
with our firm and you have the option to purchase investment products that we recommend through
other brokers or agents that are not affiliated with our firm.

Cash Sweeps
Cash pending investment in your advisory account will be swept into an FDIC cash sweep program,
unless otherwise requested. The money held in The FDIC Cash Sweep Program contains banks that
are insured by the Federal Deposit Insurance Corporation ("FDIC"). The bank, our custodian Pershing,
and our firm will receive economic benefit in the form of revenue sharing based on the deposits in the
program. Therefore, the rate you receive is often a lower rate of return on the money deposited than on
other investment alternatives. The program is not obligated to offer the highest interest rates available
or comparable to other Money Funds. This creates a conflict of interest because we have a financial
incentive to recommend the FDIC Cash Sweep Program which shares compensation with us over
those that do not and/or investment in Money Funds which do not share revenue with our firm.
Similarly, compensation for balances in other Sweep Products such as Money Market Funds, is
received by the Funds, Pershing, and our Firm. More information can be found at
www.pershing.com/rates.

Use of Margin
We may offer more sophisticated investment strategies such as margin in the managed account
program. Fees for advice and execution on these securities are based on the total net asset value of
the account. The use of margin may also result in interest charges in addition to all other fees and
expenses associated with the security involved. In the cases where margin debit interest is charged to
your account, we receive a portion of the interest charged, presenting a conflict of interest.

Any material conflicts of interest between you and our firm, or our employees are disclosed in this
Disclosure Brochure. If at any time, additional material conflicts of interest develop, we will provide you
with written notification of the material conflicts of interest or an updated Disclosure Brochure.

Item 7 Types of Clients
We offer investment advisory services to individuals, pension and profit sharing plans, trusts, estates,
charitable organizations, corporations, and other business entities.

In general, we do not require a minimum dollar amount to open and maintain an advisory account;
however, we have the right to terminate your Account if it falls below a minimum size, which, in our
sole opinion, is too small to effectively manage.

Among other criteria, clients, who are charged performance-based fees, must have at least $1,000,000
under management with us or they will certify to us that they have a net worth of at least $2,000,000
(excluding the value of their primary residence) at the time of entering into the performance based fee
arrangement. However, clients who entered into a performance-based fee arrangement with our firm
prior to September 19, 2011, and who have met the previously defined financial and other relevant
criteria may have entered into such fee arrangements under lower financial thresholds according to
then current federal rules and regulations.