Empire Financial Management Company, LLC

Empire Financial Management Company, LLC is a New York State Limited Liability Company registered with the U.S. Securities and Exchange Commission as an Investment Adviser. Established in January 2008, the firm offers asset management programs to separate account clients with a minimum of $100,000 of assets under management per account. Services may be discretionary and/or non-discretionary, tailored to individual needs. The firm charges annualized asset-based fees ranging from approximately 0.5% to 2.5% based on a sliding scale of assets under management, calculated quarterly. Client accounts are reviewed quarterly by the Managing Member to ensure conformity with objectives and guidelines. The firm may have discretionary investment authority over client assets and does not have the authority to vote proxies. Client accounts are held at RBC, and the firm does not solicit prepayment of management fees exceeding $1,200 six months in advance. The firm does not have any financial conditions likely to impair meeting contractual commitments to clients and has not been subject to a bankruptcy petition in the past ten years.