1919 Investment Counsel LLC

ITEM 5. FEES AND COMPENSATION
Generally, clients pay a management fee on a quarterly basis based on the client’s aggregated assets under management with
1919 at that point in time. The fee schedule set forth below is 1919’s standard fee schedule as of January 1, 2026. Fees vary
for a variety of circumstances that include, but are not limited to, (i) clients who opened accounts under prior fee schedules,
(ii) clients who transition their accounts to 1919 from a firm that is affiliated with, or acquired by, 1919, (iii) clients who obtain
1919 investment advisory services pursuant to agreements such clients have with other firms, such as wrap fee program
sponsors and 1919 affiliates, Stifel Trust Company, National Association (“Stifel Trust”) and Stifel, Nicolaus & Company,
Incorporated (“Stifel Nicolaus”), or (iv) clients who have greater servicing needs. Additionally, fees may vary if a client is
accessing 1919’s investment advisory services through select programs at unaffiliated firms. 1919 and clients will mutually
agree to a fee structure prior to entering into an agreement. Clients have the option to purchase investment products that 1919
recommends through brokers or agents that are not affiliated with us.

                                     Individual Accounts
    Account
                     Based on a $2 million minimum account or client                          Institutional Accounts
     Type
                                        relationship
                        1.00% on the first $3 million under management           0.75% on the first $10 million under management
   Equity /
   Balanced            0.70% on the next $7 million under management             0.60% on the next $15 million under management
   (excluding          0.50% on the next $30 million under management            0.50% on the next $25 million under management
  AKIA clients)
                                     0.40% on the balance                                      0.40% on the balance
                        0.50% on the first $3 million under management           0.30% on the first $10 million under management
     Fixed
   Income               0.35% on the next $7 million under management            0.20% on the next $15 million under management
   (excluding          0.25% on the next $30 million under management            0.15% on the next $25 million under management
  AKIA clients)
                                     0.20% on the balance                                      0.10% on the balance
     AKIA                 0.50% to 1.00% of assets under management                 0.50% to 1.00% of assets under management

Clients may request to “household” accounts serviced by 1919 (that is, group accounts of different clients together when those
clients have a pre-existing relationship to one another for an aggregate value that qualifies for a lower fee tier). It is a client’s
responsibility to determine whether they have multiple accounts that could be placed in a billing household and potentially
result in lower overall fees. Special tax rules may apply to the inclusion of IRAs and Keogh plans in a household, and 1919
may decline requests to combine retirement accounts subject to ERISA with non-retirement accounts into a single fee
household. Requests for alternative fee arrangements are considered using several factors – such as longevity of relationship,
aggregate assets under management across asset types, and requested additional services (e.g., 1919’s family office or financial
planning services) - and approval is at 1919’s discretion.

Wrap Fees

In a wrap fee program, a client pays an asset-based fee to the program sponsor that typically covers the sponsor’s investment
advisory and custody services, and the cost of brokerage transactions executed by the sponsor or by a broker- dealer designated
by the sponsor. 1919’s fees are included in the wrap fee when 1919’s Wrap Fee Strategy manages the client’s wrap fee account.
If managed outside of 1919’s Wrap Fee Strategy, clients pay 1919 a fee for such investment management services that is
separate from the wrap fee paid to the sponsor. Clients with accounts in a wrap fee program should contact the program’s
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sponsor for information regarding fees and expenses associated with program accounts.

Employee Investment Programs

1919 offers certain investment programs exclusively to 1919 employees, and their children, parents, and in-laws. The standard
fee rates and minimum account sizes for these programs are as follows:

               Program                      Minimum Account Size                                     Fees
                                                                                   Range of 0.35% to 0.50% of assets under
   Fund Asset Allocation Program                     $10,000
                                                                                                  management
                                                                                Equity: Range of 0.35% to 0.50% of assets under
                                                                                                  management
   Investment Strategies Program                    $100,000
                                                                               Fixed Income: Range of 0.15% to 0.25% of assets
                                                                                             under management
                                                                               Range of 25% to 50% discount to the fee schedule
                                                                                                   below:
                                                   $500,000
    Tailored Investment Strategy                                                1.00% on the first $3 million under management
                                             (Minimum Relationship)
...

ITEM 7. TYPES OF CLIENTS
1919 provides investment advisory services to high-net-worth individuals and families, endowments, foundations, other
charitable organizations, public/government-related clients, pension and profit-sharing plans, investment companies,
corporations, individual retirement plans, partnerships, trusts, and estates. For new client accounts and relationships, 1919
generally charges the minimums described in Item 5 of this brochure. As described in Item 5, 1919, in its sole discretion, can
waive otherwise applicable minimums for any one or more clients.

In addition, 1919 reserves the right to refuse or terminate business for any reason, except as otherwise prohibited by law, even
if such business would meet applicable standard 1919 account and relationship minimums in accordance with the investment
advisory agreement or applicable services agreement.