Aventura Capital Management LLC

Fees and Compensation
Fees for Advisory Services. In the event the client determines to engage the Company to provide
investment management services, the Company shall do so on a fee basis. If engaged, the Company shall
charge an annual fee based upon the percentage of the market value of assets being managed b y the
Company. The annual fee shall vary between (.70% and 1.50%) depending upon the market value of the
assets under management and the type of investment management services to be rendered, as follows:

BASIC FEE SCHEDULE

Portfolio Value                               Annual Management Fee
Under $500,000                                       1.50%
$ 500,000 - $999,999                                 1.25%
$1,000,000 - $2,499,999                              1.00%
$2,500,000 - $4,999,999                              0.80%
$5,000,000 and above                                 0.70%

Our management fee is billed on a quarterly basis, in advance, based upon the average end of
month balances from the previous calendar quarter. The initial bill will include fees for the initial
partial quarter, calculated in arrears, on a prorated basis from the day the first deposit was made

Aventura Capital Management, LLC
FORM ADV Part 2A and Part 2B
March 27, 2026

to the account. All accounts within the same family (husband, wife, and minor children) can be
linked to qualify for fee breakpoints. It is the client’s responsibility to notify us if any of your
accounts qualify for these discounts. Once your quarterly fee has been calculated and deducted
by us, no fee adjustments will be made for additional assets deposited into the account or partial
withdrawals taken from the account during that quarter.

Fees are generally not negotiable; however, in certain circumstances, the Company may accept
other negotiated rates. In our sole discretion, we may negotiate to charge a lesser management
fee based upon criteria determined by the Company at such time, which may include anticipated
future earning capacity, anticipated future additional assets, dollar amount of assets to be
managed, related accounts, account compensation, pre-existing client, account retention, pro
bono activities and/or other criteria.

Deduction of Investment Management Fee. In most instances, the Company’s annual
investment management fees shall be deducted quarterly from each client’s account. In such
instances, the Company’s Investment Management Agreement and the client’s agreement with
custodian and/or clearing firm shall authorize the custodian or clearing firm to debit the account
for the amount of the Company’s investment management fee and to directly remit that
management fee to the Company in accordance with required procedures established by the
SEC. Specifically, the custodian or clearing firm must send account statements to the Company’s
clients at least quarterly showing all disbursements from the account, including the amount of
the Company’s investment management fee. While in some instances the Company may bill a
client instead of having fees deducted directly from a client’s account, such billing is permitted
by only in the Company’s sole discretion and is not an option that clients may generally select.

Other Types of Fees and Expenses. Our annual fees are exclusive of, and in addition to, other
fees, costs and expenses related to the management of your account. You may incur certain
charges imposed by exchanges, custodians, brokers, third party investment and other third
parties such as commissions, markups or markdowns, fees charged by managers, custodial fees,
deferred sales charges, odd-lot differentials, regulatory fees, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions.
Mutual funds and exchange traded funds also charge internal management fees, which are
disclosed in the fund’s prospectus. Such charges, fees and commissions are exclusive of and in
addition to our fee. While we do not receive any portion of these additional fees directly, if the
client has chosen Aventura Securities LLC as a broker-dealer (one of the Company’s affiliates), it
will receive a portion of certain of these additional fees.

Advance Payment. The Company requires advance payment of the quarterly amount its annual
investment management fee. In the event that the client terminates its Investment Management
Agreement with the Company in writing prior to the end of a calendar quarter, a pro-rated
amount of the investment management fee shall be refunded to the client.

Aventura Capital Management, LLC
FORM ADV Part 2A and Part 2B
March 27, 2026

Compensation to Supervised Persons. Certain of the Company’s supervised persons are also
registered representatives of our affiliate, Aventura Securities, LLC, will receive compensation for
the sale of securities as indicated on the customer’s confirm consistent with the customer’s
Investment Management Agreement(including commissions or service fees), insurance products
or other investment products, including asset-based sales charges or services fees from the sale
of mutual funds (collectively “Sales Related Compensation”). These charges are in addition to
the customers investment management fee paid to the Firm. The client should be aware that the
stated fees set payable to our affiliated broker-dealer, Aventura Securities, LLC in the Firm’s Investment
Management Agreement may be reduced under certain circumstances to enable us to seek to maximize
the benefit to the customer.

    •   Conflict of Interest. Receipt of Sales Related Compensation creates a conflict of interest
        and gives the supervised person an incentive to recommend investment products based
        on the sales compensation received, rather than on the client’s needs. In general, the
        Company addresses this conflict of interest through an independent review of such
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Types of Clients
The Company provides advisory services to individuals, pension and profit sharing plans, trusts,
estates, charitable organizations, corporations and other business entities. However, the
Company may begin providing advisory services to other types of clients at any time.

Generally, the Company does not require a minimum amount to open or maintain an advisory
account. We may refuse to accept any client in our sole discretion.

Methods of Analysis, Investment Strategies and Risk of Loss
Investment advice may be offered on any investments held by a client at the start of the
advisory relationship. New discretionary investments made on behalf of clients will typically be
limited to domestic and foreign equity securities and options, corporate debt securities,
municipal and United States government securities, mutual funds and variable annuities.

Methods of Analysis. We use the following methods of analysis in formulating our investment
advice and/or managing client assets:

•   Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at
    economic and financial factors (including the overall economy, industry conditions, and the
    financial condition and management of the company itself) to determine if the company is
    underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be
    time to sell).

    Fundamental analysis does not attempt to anticipate market movements. This presents a
    potential risk, as the price of a security can move up or down along with the overall market
    regardless of the economic and financial factors considered in evaluating the stock.

•   Asset Allocation. For certain clients we attempt to identify an appropriate ratio of
    securities, fixed income, and cash suitable to the client’s investment goals and risk
    tolerance.

Aventura Capital Management, LLC
FORM ADV Part 2A and Part 2B
March 27, 2026

    A risk of asset allocation is that the client may not participate in sharp increases in a
    particular security, industry or market sector. Another risk is that the ratio of securities,
    fixed income, and cash will change over time due to stock and market movements and, if
    not corrected, will no longer be appropriate for the client’s goals.

•   Mutual Fund and/or ETF Analysis. We look at the experience and track record of the
    manager of the mutual fund or ETF in an attempt to determine if that manager has
    demonstrated an ability to invest over a period of time and in different economic
    conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to
    determine if there is significant overlap in the underlying investments held in another
    fund(s) in the client’s portfolio. We also monitor the funds or ETFs in an attempt to
    determine if they are continuing to follow their stated investment strategy.

    A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past
    performance does not guarantee future results. A manager who has been successful may
    not be able to replicate that success in the future. In addition, as we do not control the
    underlying investments in a fund or ETF, managers of different funds held by the client may
    purchase the same security, increasing the risk to the client if that security were to fall in
    value. There is also a risk that a manager may deviate from the stated investment mandate
    or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s
    portfolio.

•   Risks for all forms of analysis. Our securities analysis methods rely on the assumption that
    the companies whose securities we purchase and sell, the rating agencies that review these
    securities, and other publicly-available sources of information about these securities, are
    providing accurate and unbiased data. While we are alert to indications that data may be
    incorrect, there is always a risk that our analysis may be compromised by inaccurate or
    misleading information.

Investment Strategies. We use the following strategy(ies) in managing client accounts,
provided that such strategy(ies) are appropriate to the needs of the client and consistent with
the client's investment objectives, risk tolerance, and time horizons, among other
considerations:

•   Long-term purchases. We purchase securities with the idea of holding them in the client's
    account for a year or longer. Typically we employ this strategy when:
       ▪ we believe the securities to be currently undervalued, and/or
       ▪ we want exposure to a particular asset class over time, regardless of the current
           projection for this class.

    The most material risk in a long-term purchase strategy is that by holding the security for

Aventura Capital Management, LLC
FORM ADV Part 2A and Part 2B
March 27, 2026

    this length of time, we may not take advantage of short-term gains that could be profitable
    to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value
    before we make the decision to sell.

•   Short-term purchases. When utilizing this strategy, we purchase securities with the idea of
    selling them within a relatively short time (typically a year or less). We do this in an attempt
    to take advantage of conditions that we believe will soon result in a price swing in the
    securities we purchase.

    The most material risks in a short-term trading strategy are price movement and frequency
    of trading. A short-term purchase strategy poses risks should the anticipated price swing
    not materialize; we are then left with the option of having a long-term investment in a
    security that was designed to be a short-term purchase, or potentially taking a loss.

    In addition, this strategy involves more frequent trading than does a longer -term strategy,
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