Sgroi Wealth Advisory Group LLC

Item 5 - Fees and Compensation

Description of Fees

   The Firm’s fees are reflective of Sgroi Wealth Advisory’s policy of providing
   personalized high-quality service to our clients.

   Consulting Services Fees
   Fees charged by Sgroi Wealth Advisory for consulting services are dependent upon the
   services rendered to the client and may be either fixed or hourly. The specific services
   in these areas elected by the client, and their respective fees, are defined in the
   Consulting Services Agreement executed with the client upon engaging the services
   of the Firm. Fees for consulting services may be negotiable or waived at the discretion
   of the IAR or the Firm.

   Consulting services generally entail ongoing discussions and/or reviews of generalized
   advisory issues not specifically related to financial planning or investment management
   (i.e. divorce consulting). These services are usually provided on a limited or ongoing
   basis, as defined by specific client needs and outlined in their Financial Planning &
   Consulting Agreement. Clients are billed on an hourly fee basis at the Firm’s standard rate

of $250 per hour, in fifteen (15) minute increments.

Consulting services are billed to clients either upon completion of each specific
consultation or cumulatively on a quarterly basis for ongoing consulting services, as
specified in the Agreement. For the services billed upon completion of work, Sgroi
Wealth Advisory will send an invoice to the client, which will include the number of
hours spent and the amount due and payable. For clients receiving ongoing consulting
services, the Firm will send an invoice at the end of each quarter, which will outline the
hours and amount due and payable.

Investment Management Services Fee
Clients utilizing Sgroi Wealth Advisory’s ongoing investment management services are
required to execute an Investment Management Agreement and Investment Policy
Statement or Client Profile, which define each client’s investment objectives and risk
parameters, the management services to be provided by the Firm and the investment
management fee to be charged for those services. The fee for those management
services is based on a percentage of the market value of assets under management at
the end of each calendar quarter and billed in advance for the next quarter.

For the purpose of fee calculation, only client assets managed by the Firm are aggregated,
affording the client the lowest fee percentage whenever possible. For billing purposes
only, the value of a Client’s assets under management with be aggregated with the asset
under management values of a client’s husband, wife, domestic partner, son, or daughter
living at the same mailing address, which will potentially lower the applicable asset
management fee assessed with Sgroi Wealth Advisory Group. Any potential fee
aggregation for the MWP portfolios will be done in accordance with LPL’s direction, As
previously noted, the Firm will allocate client assets to management models mutually
agreed upon with the client and consistent with each client’s investment objectives and
suitability parameters.

As previously stated, investment management fees are negotiable, on a case-by-case
basis and at the discretion of the Firm and usually based on the complexity of services
and specific needs of a client. Unless stipulated otherwise in a client’s Investment
Management Agreement, annual investment management fees for clients utilizing
Charles Schwab as their custodian and engaging the Firm for investment management
services are as follows:

                Account Value                      Annual Advisory Fee
             < $250,000                                  1.25%
            $250,000 - $1,000,000                        1.00%
            $1,000,001 - $2,500,000                      0.85%

            $2,500,001 - $5,000,000                       0.60%
            > $5,000,000                                  0.50%

            Fixed Income Only                              0.50%

Clients utilizing IPX Retirement as custodian of their 403(b) accounts are assessed an
annual fixed management fee that is based on a percentage of the client’s total assets
under management (including cash, cash equivalents, and margin balance). The fee
ranges from 0.50% to 1.25% and is determined by the Firm based on the complexity
of services and specific needs of a client. In general, investment management fees may
be reduced by the advisor at any time, with notification of the reduction relayed to the
client.

When a client has a managed account that is set up as a margin account, the Firm’s
investment management fee will be based on the full value of the account’s assets
under management without regard to the amount of margin debt on the account.
Clients need to be aware that buying investments using margin increases the amount
of fees paid to Sgroi Wealth Advisory. This creates a conflict of interest. In addition, a
client with a margin account is charged margin interest by the custodian on the margin
debit balance in the client’s account. Please refer to Items 4 and 8 for additional
information regarding the conflicts and risks surrounding margin accounts.

Clients utilizing SpiderRock Platform Servies, LLC, a sub-adviser of Sgroi Wealth
Advisory Group, hereinafter SpiderRock, shall be charged a fee of approximately 0.50%
– 0.85%, depending on the type of service elected by the client, directly payable to
SpiderRock, along with a management fee determined by the advisor on a case-by-case
basis. Clients utilizing Aperio Group, LLC, hereinafter Aperio, a sub-adviser of Sgroi
Wealth Advisory Group, shall be charged a fee of approximately 0.22% directly payable
to Aperio, along with a management fee determined by the advisor on a case-by-case
basis.

All investment management fees are billed quarterly in advance and are based on a
...

Item 7 - Types of Clients

Description
    Sgroi Wealth Advisory’s clients are comprised primarily of individuals but also include
    high net worth individuals, corporations, and pension and profit-sharing plans. Client
    relationships vary in scope and length of service.

Account Minimums and Other Conditions
   Sgroi Wealth Advisory does not require a minimum account size to engage a new
    client or retain an existing client. Investment Management fees, however, do vary based
    on the amount of assets under management by the Firm and clients with smaller
    accounts pay a higher percentage rate on their annual fees than the fees paid by clients
    with greater amount of assets under management.

    When the Firm provides investment advice to a client, the Firm is deemed a fiduciary
    under certain federal regulations, and within the meaning of Title I of the Employee
    Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code, as
    applicable, which are laws governing retirement accounts. The way the Firm makes
    money creates conflicts of interest; however, as a fiduciary, Sgroi Wealth Advisory and
    the Firm’s supervised persons are required to always act in clients’ best interests, which
    means the Firm and our supervised persons must, at a minimum take the following
    steps:

       •  Meet a professional standard of loyalty and care when making investment
          recommendations.
       • Always put our clients’ interests ahead of our own when making
          recommendations and providing services.
       • Disclose all conflicts of interest and how the Firm addresses such conflicts.
        • Adopt and follow policies and procedures designed to help ensure that we give
          advice and provide services that remain in each client’s best interest.

       •   Charge an advisory fee that is reasonable for our services.
       •   Not provide, or withhold, any information that could render our advice and/or
           services misleading.

    If a client’s account is a pension or other employee benefit plan governed by ERISA, the
    Firm may be an ERISA fiduciary to the plan. In providing investment management
    services, the sole standard of care imposed upon the Firm is to act with the care, skill,
    prudence and diligence under the circumstances then prevailing that a prudent man
    acting in a like capacity and familiar with such matters would use in the conduct of an
    enterprise of a like character and with like aims. Sgroi Wealth Advisory will provide
    certain required disclosures to the “responsible plan fiduciary” (as such term is defined
    in ERISA) in accordance with Section 408(b)(2), regarding the services the Firm
    provides and the direct and indirect compensation received from such clients. Generally,
    these disclosures are contained in this Form ADV Part 2A, the Client Agreement and/or
    in separate ERISA disclosure documents and are designed to enable the ERISA plan’s
    fiduciary to: (1) determine the reasonableness of all compensation received by Sgroi
    Wealth Advisory ; (2) identify any potential conflicts of interests; and (3) satisfy
    reporting and disclosure requirements to plan participants.