RS Crum Inc. usually charges on a fixed/flat fee (retainer) or on a percentage of assets under management. Any fee may take into consideration the scope and complexity of the services provided, the value of assets managed, the number of accounts and/or the individual needs of the client. Fees are negotiable and are discussed and agreed upon with clients prior to the beginning of services.

A percentage fee schedule is applied on a scale based on a client’s assets under management as follows.

Assets Under Management (AUM)	Annual Percentage
Up to $1.0 million	1.0%
From $1.0 million to $3.0 million	0.8%
In excess of $3.0 million	0.6%

The specific manner fees are charged is established in a client’s written Advisory Agreement. The Firm will generally bill its fees quarterly or monthly in advance. Lower fees for comparable services may be available from other sources.

For the majority of clients, RS Crum Inc. accepts the authority to bill (debit) client account(s) directly for fees. Clients receive an informational invoice prior to fees being debited. Normally, fees are withdrawn

within ten (5) business days after the invoice date. The custodian withdraws advisory fees from the

client’s account based on our instruction, as outlined in our Advisory Agreement. All clients will receive brokerage statements from the custodian no less frequently than quarterly that will show the deduction of the advisory fee.

RS Crum Inc. will send an invoice to all clients who choose not to have advisory fees withdrawn directly from their custodian account and clients can pay management fees by check. The invoice is payable upon receipt and will include the fee calculation and amount due. Clients are billed by the Firm on the schedule set forth in their Advisory Agreement.

RS Crum Inc.’s 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 providers and other 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 RS Crum Inc.’s fee. RS Crum Inc. does not receive any portion of these commissions, fees, and costs.

Item 12 – Brokerage Practices further describes the factors that RS Crum Inc. considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions).

Cancellation of Services (Limited Duration or Continuous)

Services can be cancelled by either party at any time without penalty by written notice. Clients shall be charged pro rata for services provided through the date of termination. If the client made an advance payment, RS Crum Inc. will refund any unearned portion of the advanced payment.