Aperio Group LLC

ITEM 5: FEES AND COMPENSATION

Fee Agreements – General
Aperio’s fee arrangements for its investment management services vary by client and
are based on a number of different factors, including investment mandate, services
performed, and account/relationship size.

Typically, Aperio negotiates fees with Wrap Sponsors and Intermediaries, including
Intermediaries that provide access to TAMPs, and not directly with clients
participating in such programs. However, for specialized portfolio customization,
additional fees may be charged based on the size and complexity of the account(s). In
the event of fee schedule changes, Aperio reserves the right to continue pre-
established fee schedules with current clients that may be more or less advantageous
to such clients than the new or changed fee schedules offered to prospective clients.
Additionally, Aperio reserves the right to offer prospective clients fee schedules or
terms that may be more or less advantageous to such prospective clients than the
existing fee schedules offered to its current clients for similar services.

Separate Account Indexing
Aperio charges an annual management fee based on a percentage of a client’s account
value for all separately managed equity index strategies managed by Aperio. However,
accounts may be charged additional fees for certain customization options, such as
pass-through costs of licensing data for specialized indexes or premiums for
implementing long/short equity strategies. Fees are negotiable at the sole discretion of
Aperio and vary depending on account size, account parameters, and overall
relationship. A minimum annual fee may be applied in certain cases, which can result in
a higher effective fee rate than set forth below; however, Aperio has discretion to lower
or waive the minimum at any time and for any client(s).

Standard annual advisory fee rates are set forth below, based on the client account’s
chosen benchmark index for the implemented investment strategy:

Different annual advisory fee rates apply to long-short strategies, as described in
more detail below.

Wrap Fees
The annual fees received by Aperio from each Wrap Sponsor are generally equal to
either: (a) a percentage of the total assets in the Wrap Sponsor’s Wrap Program
accounts for which Aperio provides investment management services; or (b) a

 Aperio Group, LLC
 Form ADV, Part 2A
 March 31st, 2026

percentage of the Wrap Fees actually collected by the Wrap Sponsor from Wrap
Clients to whom Aperio provides investment management services.

Each Wrap Sponsor generally pays Aperio on a quarterly basis, generally in advance,
or as outlined in each written agreement between Aperio and the Wrap Sponsor. With
respect to each Wrap Program in which we participate, the standard fees received by
Aperio from each Wrap Sponsor can vary depending on the investment style selected
and other factors. The annual fees currently range up to 0.40%, depending on the
product offered.

Aperio is not informed of the specific fee arrangement negotiated between each Wrap
Client and the Wrap Sponsor. Wrap Sponsors charge a minimum annual Wrap Fee to
each of their Wrap Clients. Complete information on the services provided and fees
charged under a Wrap Program can be found in each Wrap Sponsor’s Wrap Fee
Program Brochure. Wrap Clients should carefully evaluate all information in the
applicable brochure to determine whether or not the Wrap Fee paid for the services
provided exceeds the aggregate cost of such services if they were to be provided
separately.

Aperio negotiates fees with some clients who pay lower fees than the fees shown
above. Also, lower fees for comparable services may be available from other sources.

Mutual Fund Clients
For our sub-advised mutual fund clients, we receive annual sub-advisory fees, which
are based on the funds’ average daily net assets. The annual sub-advisory fees are
paid monthly in arrears by the funds’ advisers and range from 0.08% to 0.20%.

Deduction of Fees
The consent for deduction of fees is generally contained in the written agreement into
which each client enters with Aperio, or otherwise is contained in the Master Sub-
Advisory Agreement between Aperio and each client’s financial advisor (Intermediary).
In some cases, clients or their Intermediary may negotiate different billing terms, such
as requiring direct invoices and providing payment through means other than
deduction of fees directly from the client’s custodial account.

Clients’ custodians will deliver a periodic (at least quarterly) account statement
directly to clients. The statement will include all transactions that took place in the
account during the period covered and reflect any advisory fees deducted and paid to
Aperio. Clients are encouraged to review their account statements for accuracy and
compare them to the reports received from Aperio, if applicable. Should there be any
discrepancies, clients should rely on the information in their custodians’ account
statements.

Other Fees
Clients should understand that the fees discussed above are specific to what Aperio
charges and do not include certain charges that may be imposed by third parties,
such as custodial fees, exchange-traded fund and mutual fund fees and expenses,
and additional fees charged by Wrap Sponsors (although we have generally described
some of those additional fees in specific sections of this Brochure.) Client assets also
can be, depending on the type of account and the types of investments in the account,

 Aperio Group, LLC
 Form ADV, Part 2A
 March 31st, 2026

subject to asset-based transaction fees, brokerage fees and commissions, and other
fees and taxes on brokerage accounts and securities transactions. For clients with
accounts that trade foreign ordinary securities, settlement timing may lead to
overdraft fees charged to a client by the client’s custodian. For those clients using
strategies involving selling securities short, they will be subject to margin fees and
...

ITEM 7: TYPES OF CLIENTS

Description
As discussed in Item 4 (“Advisory Business”) of this Brochure, Aperio clients generally
include the following:

•     Registered Investment Advisers and Consultants;
•     Family and Multi-Family Offices;
•     Individuals, High-Net-Worth Individuals, and Trusts;
•     Charitable Organizations including Endowments and Foundations;
•     Pooled Investment Vehicles, including Private Funds;
•     Investment Companies, including Registered Mutual Funds;
•     Wrap Programs and Other Wealth Management Platforms;
•     Pension and Profit-Sharing Retirement Plans; and
•     Turnkey Asset Management Platforms.
For registered investment advisors and consultants, their clients may include, but are
not limited to: financial institutions, registered investment companies, pension funds
and other retirement accounts, insurance companies, charitable and endowment
organizations, corporations, limited liability companies, banks and thrift institutions,
estates and trusts, and other institutional type accounts (both taxable and tax-
exempt), government agencies, government-chartered corporations, quasi-
governmental agencies, state and local governments and non-U.S. pension funds,
national banks, as well as high-net-worth and other individuals and family offices.

For ERISA clients, Aperio provides certain required disclosures to the “responsible
plan fiduciary” (as such term is defined in ERISA) in accordance with Section
408(b)(2), regarding the services we provide and the direct and indirect compensation
we receive from such clients. Generally, these disclosures are contained in this
Brochure, in the client agreement, and in separate ERISA disclosure documents, and
are designed to enable the ERISA plan’s fiduciary to: (1) determine the reasonableness
of all compensation received by Aperio; (2) identify any potential conflicts of interests;
and (3) satisfy reporting and disclosure requirements to plan participants.

Conditions for Managing Accounts
Aperio has several conditions for managing client accounts.

For accounts managed by Aperio, both through an Intermediary or directly, the client
must use the services of a custodian to hold the securities in their account. For Aperio

 Aperio Group, LLC
 Form ADV, Part 2A
 March 31st, 2026

to accept an account for management, Aperio must have an established relationship
with that custodian or alternatively must agree to establish one. The client is required
to grant Aperio the authority to manage their account by signing a Limited Power of
Attorney or other similar agreement with their custodian.

The client is also required to grant Aperio the authority to manage their account by
entering into an individual Investment Advisory Agreement, or their Intermediary
entering into a Master Sub-Advisory Agreement, which grants Aperio discretionary
authority to manage the portfolio according to agreed-upon guidelines, to buy and
sell securities, invest cash, implement client instructions, deduct fees, and perform
other actions consistent with managing the portfolio.

Wrap Program accounts are usually subject to minimum account sizes and program
fees in addition to Aperio fees, which are outlined in the Wrap Sponsor’s ADV, Part 2A–
Appendix 1.

There may be times when certain restrictions are placed by a client that prevent us
from accepting or continuing to service the client’s account. Aperio reserves the right
not to accept and/or to terminate a client’s account if it feels that the client-imposed
restrictions would limit or prevent it from meeting and/or maintaining its objectives.
Furthermore, pursuant to provisions in the Investment Advisory Agreement, Aperio
may elect to terminate a client should changes occur to client-imposed restrictions,
client investment objectives, and/or other business or regulatory circumstances
where Aperio believes it can no longer manage the client’s assets effectively.

Please see the discussion in Item 11 for further information regarding potential
restrictions on Aperio as a BlackRock-affiliated Investment Adviser.