A. Description of Advisory Services American Alpha Advisors, LLC dba Domani Advisors (hereinafter, “AAA”) primarily offers ongoing Investment Management and Reporting Services to Clients. AAA provides advisory services to Clients through individuals registered as investment adviser representatives (“IARs”). AAAis the sponsor of the wrap fee program. Our wrap fee program allows you to pay a single fee that covers advisory services, trade execution, custody and other standard brokerage services.
AAA offers ongoing wrap fee portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each Client. AAA creates an Investment Policy Statement for each Client, which outlines the Client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following:
•Determine investment strategy•Personal investment policy
•Asset allocation•Security selection
•Assessment of risk tolerance•Ongoing portfolio monitoring AAA evaluates the current investments of each Client with respect to their risk tolerance levels and time horizon. AAA will request discretionary authority from Clients in order to select securities and execute transactions without permission from the Client prior to each transaction.
Risk tolerance levels are documented in the Investment Policy Statement, which is given to each Client.
B. Compensation for Advisory Services AAA charges a single asset-based fee for services covered by the wrap program. AAA’s annual fee for advisory services follows a tiered (blended) fee schedule: Assets Under ManagementIncremental Fee Rate 0- 1,000,0001.00% 1,000,000- 2,000,0000.80% 2,000,000- 10,000,0000.70% 10,000,000- 20,000,0000.60% 20,000,000- 50,000,0000.50% 50,000,000- 100,000,0000.40% 100,000,000- 200,000,0000.30% 200,000,000 +0.20% The advisory fee is calculated by multiplying the incremental fee rate for each range of AUM. AAA bills in arrears and the advisory fee is calculated using the value of the assets on the last business day of the billing period. Tiered fee schedules can be billed based on household market values.
AAA generally bills monthly based on the following calculation: Sample Computation 𝐴𝑛𝑛𝑢𝑎𝑙 𝐹𝑒𝑒 𝑅𝑎𝑡𝑒 % ∗ 𝐴𝑈𝑀 Fees are negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of AAA’s fees within five business days of signing the Investment Advisory Contract. Thereafter, Clients may terminate the Investment Advisory Contract with 30 days written notice. AAA believes that its advisory fees are reasonable, but the firm’s fees may be more than the cost of purchasing the same or comparable services through other investment advisors. AAA may, in its sole discretion, reduce, waive or calculate differently fts fee with respect to certain Clients, including employees or family members.
Portfolio management fees are withdrawn directly from the Client’s accounts with Client’s written authorization on a monthly basis. Fees are paid in arrears. AAA 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.
Schwab’s Brokerage Services In addition to the advisory services,

the wrap fee program includes certain brokerage services of TD Ameritrade Institutional and Schwab Advisor Services, both part of Charles Schwab & Co., Inc. (“Schwab”) a broker-dealer registered with the Securities and Exchange Commission and a member of FINRA and SIPC. AAA is independently owned and operated and not affiliated with Schwab. Schwab will act solely as a broker-dealer and not as an investment advisor. Schwab will have no discretion over Client accounts and will act solely on instructions it receives from AAA or the Client. Schwab has no responsibility for AAA’s services and undertakes no duty to our Clients to monitor our Firm’s management of accounts or other services we provide.
Fees We Pay Schwab The fee Clients pay to AAA for advisory services and wrap fee, allows the Firm to pay for brokerage and execution services provided by Schwab.
C. Contributing Cost Factors You may be able to find advisory services and brokerage services elsewhere for a combined fee that is less than what you pay or will pay at AAA. The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated with managing the account, and the frequency or type of securities transactions executed in the account.
D. Additional Fees AAA will wrap third party fees for portfolio management accounts. AAA will charge Client one fee, and pay all transaction fees using the fee collected from the Client. AAA exclusively manages portfolios in a wrap fee program for the purposes of simplicity and transparent pricing. AAA receives the advisory fee stated in Item 4.B (or the Client’s Investment Advisory Agreement) as a management fee under the wrap free program.
Our wrap fee does not cover all fees and costs. Certain fees are not included in the wrap fee and are paid for separately by the Client. These include, but are not limited to, margin interest costs, charges imposed directly by a mutual fund or exchange traded fund (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, deferred sales charges, fees for trades executed away from the Custodian at another broker-dealer, odd- lot differentials, transfer taxes,wire transfer, check fees, electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions.
Conflict of Interest. When managing Client portfolios on a wrap fee basis, the more costs that are incurred for custodial, trading and other administrative costs (including execution and transaction fees), the less profitable it is to our firm. Accordingly, AAA has a conflict of interest because the Firm has a financial incentive to maximize compensation by seeking to reduce or minimize the total costs incurred in your account(s). AAA resolves this conflict of interest by treating every account invested in a particular strategy substantially the same regardless of account size and investing in the Client’s best interest.
E. Compensation of Client Participation Neither AAA, nor any representatives of AAA receive any additional compensation beyond advisory fees for the participation of Client’s in the wrap fee program. However, compensation received may be more than what would have been received if Client paid separately for investment advice, brokerage, and other services. Therefore, AAA may have a financial incentive to recommend the wrap fee program to Clients.