Breckinridge Capital Advisors Inc

ITEM 5. FEES AND COMPENSATION
Breckinridge is compensated for investment management services through the payment of asset-
based fees made by its clients. Breckinridge retains full discretion to negotiate the advisory fees
that it charges clients, in consideration of asset levels, service requirements, and any other factor
that Breckinridge deems relevant in its sole discretion. Client fees will vary. Even within the same
investment strategy, different clients will have different fee structures and schedules.
ADVISORY FEE CALCULATIONS
Advisory fees are typically calculated by Breckinridge. Effective April 1, 2026, Breckinridge
calculated fees are based on the average value of securities, including any accrued interest, in
client accounts during a calendar quarter. The average value is determined using daily account
valuations that reflect the closing market value of securities held in the account on each trading
day. Cash balances are not included in billing valuations. The daily values are aggregated over the
billing period and divided by the total number of trading days in the quarter to arrive at the average
value for billing calculation.

The securities held in client accounts are priced daily by independent pricing services. If
Breckinridge is unable to obtain a price for a security from the third-party services, Breckinridge
values the security in accordance with its then current valuation policy.

                                                              Breckinridge Capital Advisors | Page 5 of 31

Some client assets are aggregated for billing purposes. Clients with multiple accounts managed by
Breckinridge (i.e., householding) or clients who access Breckinridge through Intermediaries may
receive a lower effective rate due to the combined level of assets. Because Breckinridge is provided
with limited client information, Breckinridge does not household accounts for fee calculation
purposes unless instructed to do so by the Intermediary. Such instructions must be provided to
Breckinridge in writing. Once instructions have been acknowledged and processed, householding
will go into effect for the next billing cycle.

Breckinridge’s standard fee payment methodology requires advisory fees to be paid quarterly, in
arrears. Fees will be either deducted directly from client custodial accounts or invoiced to clients.
If a client wishes to calculate or pay advisory fees in a manner that is different from Breckinridge’s
standard, it will be the client’s responsibility to calculate the advisory fees. Clients are responsible
for verifying that their fees have been properly calculated.

When a client is responsible for calculating their own advisory fee, they may use a different
calculation, pricing source or time period than those used by Breckinridge. Breckinridge will
request documentation from the client to conduct a reasonable check but will not validate the
client’s calculation. Breckinridge does not issue invoices for any fees calculated by clients.
Breckinridge may also earn fees on cash from clients who calculate their own fees as some clients
include cash in the asset values used for billing purposes.
Other Fees and Expenses
In addition to Breckinridge’s advisory fees, underlying clients bear trading costs, taxes, and any
fees or expenses associated with custodial accounts, wire and electronic fund transfers, or
services provided by other third-party investment advisors or managers selected by the underlying
client. These costs and expenses are not included in the advisory fee paid to Breckinridge.

Clients are required to appoint their own custodians and are responsible for negotiating the terms
and arrangements for the account with that custodian. Breckinridge, therefore, is unable to
influence the transaction costs charged by the custodian to settle Breckinridge trades for their
accounts. In addition, Breckinridge investment strategies may not be available on all custodial
platforms. See Item 15 for more information on custodial arrangements.
INVESTMENT OF CLIENT ASSETS IN AFFILIATED AND UNAFFILIATED FUNDS
For clients invested in Breckinridge’s Enhanced Tax Efficient strategy (see Item 8), Breckinridge
typically invests a portion of the client’s assets in an affiliated mutual fund that does not charge an
advisory fee, i.e., a “completion fund.” Clients who are invested in the completion fund via the
Enhanced Tax Efficient strategy will bear a share of the fund’s annual operating expenses.
Breckinridge has agreed to cap the completion fund’s expenses to 30 basis points (subject to
change). If the fund’s expenses exceed the cap, Breckinridge will pay the excess. If the fund’s
expenses are below the cap, Breckinridge may be entitled to receive a reimbursement.

Additionally, the completion fund may, from time to time, invest a portion of its assets in exchange
traded funds (“ETFs”). ETFs typically charge management fees and other expenses associated with
the operation and offering of the fund. Clients invested in the completion fund will bear their
proportional share of operating expenses (up to the waiver amount) and fees associated with ETF
purchases and sales. Clients should review the completion fund’s prospectus (and other
registration documents) before investing to understand the fees and expenses that may be
applicable to their particular investment.

                                                               Breckinridge Capital Advisors | Page 6 of 31

To the extent that client accounts are invested in any unaffiliated registered funds (e.g., mutual
funds or ETFs), these funds may charge a separate layer of management, commissions, trading,
and administrative expenses, which are exclusive and in addition to Breckinridge’s advisory fee.
Breckinridge does not receive any commission or portion of the funds’ fees and expenses from
these types of investments in client accounts. Additional information on trading and custody can
be found in Items 12 and 15.
...

ITEM 7. TYPES OF CLIENTS
As described in Item 4 above, Breckinridge provides investment advisory services to individuals,
high net worth individuals, trusts, estates, charitable organizations, foundations, corporations,
investment companies registered under the Investment Company Act of 1940, Taft-Hartley plans,
public funds, and other institutional investors.

At times, Breckinridge may receive little to no information as to the identity or account structure of
an Intermediary’s end client. As such, Breckinridge may unknowingly act as adviser or sub-adviser
to a client type not identified in the above paragraph.