Adaptive Advisers LLC

Item 5. Fees and Compensation

Adaptive offers its services to Clients on a fee-free basis as described in Item 4 above.

Adaptive will be paid for its advisory services in the event a Client chooses to purchase downside protection. The fee
paid to Adaptive by ACM generally will be based upon [1] the notional (market) value of the assets under protection
(AUP) in the contract for downside protection, at the time of the contract execution; at [2] the Adaptive fee rate of
0.30% annualized (0.30% divided by 365, per calendar day), for [3] the number of calendar days in the downside
protection contract. The fee will be paid to Adaptive from ACM out of the payment received from the Client to
purchase downside protection.

The cost to purchase downside protection is largely a function of the securities portfolio to be protected, additional
market-clearing costs reflected in the pricing of the downside protection contract such as the bid-ask spread and market
fluctuations of the underlying futures and options contracts to manage the market risk of the downside protection
contract, the cost of securing capital to provide protection, the scope and duration of protection sought, and the cost
will include the fee set forth above to be paid by ACM to Adaptive.

Adaptive does not charge any form of performance-based fees.

Adaptive does not deduct fees directly from any Client accounts.

Fees Charged by Financial Institutions

As further discussed in response to Item 12 (below), Clients may incur charges imposed by broker-dealers, trust
companies, banks, etc. (collectively referred to herein as the “Financial Institution”) and other third parties such as
custodial fees, brokerage commissions, transaction fees, charges imposed directly by a mutual fund or ETF in an
account, which are disclosed in a fund’s prospectus (e.g., fund management fees and other fund expenses), 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. Clients may also pay advisory fees to their own financial advisers (not
to Adaptive), who may have discretions to purchase the downside risk management product and use other Adaptive
services on their behalf.

Fees for Management During Partial Quarters of Service

Since the Fee paid to ACM for purchase of the downside risk management product is a one-time fee paid in advance
(and ACM pays a portion thereof to Adaptive for its services) the purchase of downside protection is nonrefundable.

                                                              Adaptive Advisers, LLC Disclosure Brochure
                                                                                          March 30, 2023

Item 7. Types of Clients

Adaptive generally provides its services to individual Clients and other registered investment advisers (or their
Clients). There are no other minimum account size or other requirements imposed on Clients in order to start and
maintain a relationship with Adaptive. Adaptive does provide its services (using the Licensed Technology) to ACM
in furtherance of the sale of downside protection.

                                                              Adaptive Advisers, LLC Disclosure Brochure
                                                                                          March 30, 2023