St Nicholas Private Asset Management Inc

Item 5 – Fees and Compensation
St. Nicholas is a fee-based investment advisory service. The Firm does not currently provide newsletters or any proprietary
research publications or reports for a fee. Fees are typically calculated based upon a percentage of each account's total
assets under management. St. Nicholas maintains a published fee schedule, but fees will typically fall in the range of 0.50%
to 1.25% per year, depending upon the total size of the relationship and the services offered. Our current fee schedule is as
follows:

                                          Investment Advisor Brochure

                                 St. Nicholas Private Asset Management, Inc.

Annual Fee:                            1.25% on first $2,000,000
                                       1.00% on next $3,000,000
                                       0.50% on all assets over $5,000,000

Fees are charged quarterly in advance.

Trust Accounts may be charged additional fees by outside trustees. Any specific trustees fees go only to the outside
trustee(s) and St. Nicholas does not share or benefit financially from any trustees’ fees charged by outside trustees. In
certain circumstances, a flat fixed fee may be charged, and/or hourly charges may be negotiated for extraordinary services.
Fee structures are negotiated and provided to each individual client as part of the account opening process. Any future fee
adjustments or changes will be communicated in advance in writing to each affected client as they may occur. Clients will
also be informed that their account(s) may be subject to additional expenses apart from The Company's management fee
including but not limited to mutual fund expense/fee charges, and trading commission charges. Fees are billed quarterly
in advance and are based on trade-date values (including accruals) as of the last day of each calendar quarter. Clients whose
accounts are terminated by 30-day advanced notice will receive a pro-rated refund for collected but unearned fees based
upon the termination date.

The specific manner in which fees are charged by St. Nicholas Private is established in a client’s written agreement with St.
Nicholas. St. Nicholas will generally bill its fees on a quarterly basis. Clients are generally billed in advance each calendar
quarter. Clients may also elect to be billed directly for fees or authorize St. Nicholas Private Asset Management, Inc. to
directly debit fees from client accounts. Management fees shall not be prorated for each capital contribution and
withdrawal made during the applicable calendar quarter (with the exception of de minimis contributions and withdrawals).
Accounts initiated or terminated during a calendar quarter will be charged a prorated fee. Upon termination of any account,
any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable.

St. Nicholas’ fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall
be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investment and
other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer
taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions.
Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus.
Such charges, fees and commissions are exclusive of and in addition to St. Nicholas’ fee, and St. Nicholas shall not receive
any portion of these commissions, fees, and costs.

Item 12 further describes the factors that St. Nicholas considers in selecting or recommending broker-dealers for client
transactions and determining the reasonableness of their compensation (e.g., commissions).

Item 7 – Types of Clients
St. Nicholas provides portfolio management services to individuals, high net worth individuals, charitable institutions,
foundations, endowments, and trusts.