Sjbenen Advisory LLC

Item 5: Fees and Compensation

A. Fee Schedule

Fees for Portfolio Management

Management Style                       Annual Fee Range

Passive Management                     0.25-0.50 %

Long-Only Active Management            0.50-1.00%

Long-Short Active Management           1.00-1.50%

There is a $50,000 minimum for passive management, a $250,000 minimum for long-only
active management, and a $2,500,000 minimum for long-short active management, which
may be waived by SJBenen in its discretion. Accounts under $50,000, if accepted, will be
charged pursuant to the fee schedule above. All portfolio management fees are generally
negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory
Contract. If a client has multiple accounts under management, the maximum fee that can
be billed on any one single account is 3% per annum, but the relationship-level fee on all
accounts under management will not exceed 1.5%. Clients may terminate the agreement
without penalty for a full refund of SJBenen's fees within five business days of signing the
Investment Advisory Contract. Thereafter, clients may terminate the Investment
Advisory Contract generally with 30 days' written notice.

SJBenen uses the value of the account as of the last business day of the billing period, after
taking into account deposits and withdrawals, for purposes of determining the market
value of the assets upon which the advisory fee is based..

Financial Planning Fees

The negotiated hourly fee for these services is between $150 and $500. Clients may
terminate the agreement without penalty for a full refund of SJBenen's fees within five
business days of signing the Financial Planning Agreement. Thereafter, clients may
terminate the Financial Planning Agreement generally upon written notice.

Subscription Fees

SJBenen offers a monthly subscription newsletter, “The Benen Report.” SJBenen is not
charging a subscription fee at this time.

Investment Advisory for ERISA Plans Fees

The fees for ERISA plans range between 0.25% and 1.00% per annum on the plan assets
under management, depending on the complexity of the plan.

B. Payment of Fees

Payment of Asset-Based Portfolio Management Fees

Asset-based portfolio management fees are withdrawn directly from the client's accounts
with client's written authorization on a daily or quarterly basis, depending on the
custodian utilized. Fees are paid in arrears.

       Payment of Financial Planning Fees

       Financial planning fees are paid via check, cash, or wire. Hourly financial planning fees
       are paid in arrears upon completion.

       Payment of Subscription Fees

       SJBenen is not charging subscription fees for our newsletter at this time.

       Payment of Investment Advisory for ERISA Plans Fees

       Asset-based ERISA Plan fees are withdrawn directly from the client's accounts with
       client's written authorization on a quarterly basis, depending on the custodian utilized.
       Fees are paid in arrears.

       C. Client Responsibility For Third Party Fees

       Clients are responsible for the payment of all thirdparty 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 SJBenen. Please see Item 12 of this brochure regarding
       broker-dealer/custodian.

       D. Prepayment of Fees

       SJBenen collects its fees in arrears. It does not collect fees in advance.

       E. Outside Compensation For the Sale of Securities to Clients

       Neither SJBenen 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.

Item 7: Types of Clients

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

           ❖ Individuals

          ❖   High-Net-Worth Individuals
          ❖   Pension and Profit-Sharing Plans
          ❖   Small businesses
          ❖   Non-Profit Charitable Organizations

Minimum Account Size for Portfolio Management

There is a $50,000 minimum for passive management, a $250,000 the minimum for long-only
active management, and a $1,000,000 minimum for long-short active management, which may be
waived by SJBenen in its discretion.