Axient Investment Advisors LLC

Item 5     Fees and Compensation

Fees for Asset Management Services

The fee for our Discretionary and Non-Discretionary Asset Management services, called the Management
Fee, is negotiated between you and your Investment Advisor. Fees are calculated based on the market
value of assets under management as determined by the custodian on the last business day of the previous
billing period.

Axient Investment Advisors, LLC                                                               Page 7 of 19

The maximum annual Management Fee we charge is 2.00% of your Advisory Account’s value (excluding
Unmanaged Assets, described below). For annuity allocations, the maximum is 1.50%. The exact fee is
detailed in your Investment Advisory Agreement or the TPMM’s agreement.

We may, at your request and as an accommodation, hold an asset in your Advisory Account without
managing it (Unmanaged Assets) and we will not charge a Management Fee on it. These assets may or
may not appear in performance reports, depending on your preference. Otherwise, we calculate
Management Fees based on your account’s value on the last day of the current billing period, charged
quarterly or monthly in advance. In some cases, we may agree to charge fees in arrears or use a different
method. If you open an account mid-billing period, fees are prorated based on the number of days in the
period for which you are a client.

Management Fees are usually deducted directly from your Advisory Account, as authorized in your
agreement. In some cases, you can arrange to have fees deducted from another account or billed directly.
If you end your agreement before the billing period ends, we will refund a prorated portion of the fee by
depositing it into your account or mailing a check to your address. No fee rebate is provided for partial
withdrawals or market depreciation that do not result in termination of the advisory agreement. Once
terminated, your account will no longer be actively monitored by your Investment Advisor. You must initiate
any trading activity thereafter.

Conflicts of Interest regarding Management Fees

Higher Management Fees mean more profit for us, so we have an incentive to set higher fees or encourage
our Investment Advisor(s) to negotiate the maximum fee. We share a portion of the Management fee with
your Investment Advisor after deducting costs like TPMM fees or platform expenses. This creates a conflict,
as your Investment Advisor has an incentive to use platforms and/or investment options/models with lower
internal costs to increase their compensation. You may be able to receive or negotiate lower fees at other
firms.

Other Fees and Expenses You Pay in Connection with Asset Management.

Besides Management Fees, you will face other costs, including:

Internal fees/expenses of collective investment vehicles. If your portfolio includes mutual funds, variable
annuities, ETFs, or REITs, you will pay their internal fees, as described in their prospectuses or offering
documents.

Mutual Fund Share Classes. Mutual funds offer different share classes with varying fees. We aim to use
the lowest-cost share class available through your custodian, unless we believe a higher -cost class is
better for you (e.g., if transaction fees would outweigh the cost differenc e). Share class availability
depends on factors like your custodian, minimum investments, account type, or waivers.

12b-1 Fees. Axient and its adviser representatives do not retain 12b-1 fees. If such fees are received, they
are rebated back to the client account.

Transaction Fees. Accounts with SSI and Pershing face a $5 transaction fee per trade, though some
mutual funds (No Transaction Fee Shares or NFTs) are exempt. Some Investment Advisors may absorb
these fees, meaning some clients pay more than others. This creates a conflic t for advisors who absorb

Axient Investment Advisors, LLC                                                                Page 8 of 19

fees, as they may prefer No Transaction Fee Shares to reduce costs, thus increasing their revenue.
Axient supervises this practice to ensure that investment recommendations are not influenced by the
advisor’s decision to absorb transaction costs.

Transaction fees can add up, especially in accounts with frequent trading or many securities. In low-balance
accounts, they may exceed Management Fees. We expect at least 2-3 trades per year, with more possible
during portfolio rebalancing.

Trading Away and Step-Out Trades. In the Axient Managers Service, if a Separate Account Manager (SAM)
trades through a broker-dealer other than SSI for better execution (called “trading away” or “step-out trades”),
you will incur additional transaction fees from that broker. SAMs managing fixed-income portfolios are more
likely to trade away, increasing your costs.

Trade Aggregation. SAMs may combine client trades into a single block trade to improve execution or reduce
costs. This could affect the price you receive, as all clients in the block receive the average price. Regulations
require TPMMs to consider execution costs when choosing venues. Step-out trades may include
commissions or embedded costs, or they may be executed without extra charges.

Other Transaction-Related Expenses. Sales of equity securities may include charges to cover FINRA,
NYSE, or SEC fees (known as Section 31 Fees). Trades may also face transfer taxes or other government
charges.

Miscellaneous Custodian Fees and Charges. Your account may be subject to additional fees like wire
transfer fees, IRA fees, account transfer fees, postage fees and other fees, expense or charges, as outlined
by your custodian. These costs and charges are typically set out in a schedule of account fees provided to
you by your clearing/custodian firm.

Cash Sweep Products. When opening an SSI account, you choose how to handle cash awaiting investment.
By default, cash is swept into FDIC-insured bank accounts, but you can opt for money market mutual funds,
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Item 7    Types of Clients

We serve a variety of clients, including individuals, high-net-worth individuals, trusts, estates, corporations,
other businesses, retirement plans, pension or profit-sharing plans, and charitable organizations.

To open or maintain an Advisory Account, you must sign an agreement outlining, among other things, the
nature of our obligations and the authority given to us. Other requirements, like minimum account sizes, are
covered in Items 4 (Advisory Business) and 5 (Fees and Compensation).