Valicenti Advisory Services Inc

Item 5: Fees and Compensation

The client can determine to engage VASI to provide discretionary investment advisory
services on a fee basis. VASI's annual investment advisory fee shall be based upon a
percentage (%) of the market value of the assets placed under our management (between
0.25% and 1.00%), as set forth on the fee schedule on the Investment Advisory Agreement
between VASI and the client. VASI's standard fee schedule is 1% of the first $750,000,
3/4 of 1% on the next $750,000, and 1/2 of 1% on the remaining balance. VASI, in its
sole discretion, may charge a lesser annual investment advisory fee, charge a flat fee, or
waive its fee entirely based upon certain criteria (i.e. anticipated future earning capacity,
anticipated future additional assets, dollar amount of assets to be managed, related
accounts, account composition, complexity of the engagement, grandfathered fee
schedules, VASI employees and family members, courtesy accounts, competition
negotiations with client, etc.). PLEASE NOTE: As result of the above, similarly

Valicenti Advisory Services, Inc. Form ADV Part 2A March 12, 2026

situated clients could pay different fees. In addition, similar advisory services may be
available from other investment advisers for similar or lower fees. ANY QUESTIONS:
VASI’s Chief Compliance Officer, Jeffrey Naylor, remains available to address any
questions that a client or prospective client may have regarding advisory fees.

Clients may elect to have VASI’s advisory fees deducted from their custodial account.
Both VASI's Investment Advisory Agreement and the custodial clearing agreement may
authorize the custodian to debit the account for the amount of VASI's investment
advisory fee and to directly remit that management fee to VASI in compliance with
regulatory procedures. In the limited event that VASI bills the client directly, payment is
due upon receipt of VASI's invoice. The Investment Advisory Agreement between VASI
and the client will continue in effect until terminated by either party by written notice in
accordance with the terms of the Investment Advisory Agreement. VASI's annual
investment advisory fee shall be prorated and paid quarterly, in arrears, based upon the
market value of the assets on the last business day of the previous quarter. Upon
termination, VASI shall debit the client’s account for the pro-rated portion of the unpaid
advisory fee based upon the number of days that services were rendered during the billing
quarter. In the event that VASI is unable to deduct its fee, the client shall remain
obligated to directly remit payment to VASI upon receipt of an invoice.

As discussed above at Item 4 and below at item 12, unless the client directs otherwise or
an individual client’s circumstances require, VASI shall generally recommend that
Charles Schwab and Co., Inc. (“Schwab”) serve as the broker-dealer/custodian for client
investment management assets. Broker-dealers such as Schwab charge brokerage
commissions, transaction, and/or other type fees for effecting certain types of securities
transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and
mark-downs charged for fixed income transactions, etc.). The types of securities for
which transaction fees, commissions, and/or other type fees (as well as the amount of
those fees) shall differ depending upon the broker-dealer/custodian (while certain
custodians, including Schwab, do not currently charge fees on individual equity
transactions, (including ETFs), others do). The fees charged by Schwab, or any broker-
dealer/custodian directed by the client, are in addition to VASI’s advisory fee referenced
in Item 5 above.

Please Note-Accrued Interest/Dividends: The market value reflected on periodic
account statements issued by the account custodian may differ from the value used by
VASI for its advisory fee billing process. VASI includes the accrued value of certain
month or quarter-end interest and/or dividend payments when calculating client advisory
fees, which amounts may not yet be reflected on the custodian statement as having
been received by the account.

Tradeaway/Prime Broker Fees As indicated at Item 4 above, when in the reasonable
determination of VASI that it would be beneficial for the client, individual fixed income
transactions may be effected through broker-dealers other than the account custodian, in
which event, the client generally will incur both the fee (commission, mark-up/mark-
down) charged by the executing broker-dealer and a separate “tradeaway” and/or prime

Valicenti Advisory Services, Inc. Form ADV Part 2A March 12, 2026

broker fee charged by the account custodian (Schwab). VASI’s Chief Compliance
Officer, Jeffrey S. Naylor, remains available to address any questions that a client or
prospective client may have regarding the above.

None of VASI’s supervised persons receives selling compensation for the sale of
securities or other investment products, including asset-based sales charges or service
fees from the sale of mutual funds, including asset-based sales charges or service fees
from the sale of mutual funds.

Margin Accounts: Risks/Conflict of Interest. VASI does not recommend the use of
margin for investment purposes. A margin account is a brokerage account that allows
investors to borrow money to buy securities and/or for other non-investment borrowing
purposes. The broker/custodian charges the investor interest for the right to borrow
money and uses the securities as collateral. By using borrowed funds, the customer is
employing leverage that will magnify both account gains and losses. Should a client
determine to use margin, VASI will include the entire market value of the margined
assets when computing its advisory fee. Accordingly, VASI’s fee shall be based upon a
higher margined account value, resulting in VASI earning a correspondingly higher
advisory fee. As a result, the potential of conflict of interest arises since VASI may have
...

Item 7: Types of Clients
VASI offers to provide discretionary investment advisory services and financial services
to the extent specifically requested by a client. VASI provides service to individuals,
banks, trusts, estates, charitable organizations, pension and profit sharing plans,
corporations and business entities. As indicated above at Item 5, VASI, in its sole
discretion, may charge a lesser investment advisory fee, charge a flat fee, or waive its fee
entirely based upon certain criteria (i.e. anticipated future earning capacity, anticipated
future additional assets, dollar amount of assets to be managed, related accounts, account
composition, complexity of the engagement, grandfathered fee schedules, VASI
employees and family members, courtesy accounts, competition, negotiations with client,
etc.). Please Note: As result of the above, similarly situated clients could pay different
fees. In addition, similar advisory services may be available from other investment
advisers for similar or lower fees.

Valicenti Advisory Services, Inc. Form ADV Part 2A March 12, 2026