Carmichael Capital Inc

Item 5 – Fees and Compensation

The specific manner in which management fees (“fees”) are charged by CCI is established in each client’s written
investment advisory agreement with CCI. All fees are subject to negotiation. Our policy is to charge a management fee
ranging from 1/2% to 1% per year of the net asset value of the accounts under management. The fees are charged quarterly
in arrears (after the end of the quarter) based on the quarter-end net asset value of the accounts. At the end of each 3-
month period (a “quarter”), the value of the accounts is determined by adding the value of the securities and cash
equivalents or net cash credit balance in the accounts. The fee payable for any calendar quarter is ¼ of the agreed-upon
annual rate. Fees are prorated for each capital contribution and withdrawal made during the applicable calendar quarter
(with the exception of de minimis contributions and withdrawals). Accounts initiated or terminated during a calendar
quarter will be charged a prorated fee. Upon termination of any account, any earned, unpaid fees will be due and payable.
Clients may elect to be billed directly for fees or to authorize us to directly debit fees from their accounts. Most clients opt
for the latter. All securities held in accounts managed by CCI will be independently valued by the Custodian. The Adviser will
conduct periodic reviews of the custodian’s valuation to ensure accurate billing.

Fees are paid to CCI after the end of each calendar quarter (based on clients’ written approval to do so) and after a report
showing the fees has been provided to the custodian of the assets. The custodian also subsequently sends each client a
statement showing the amount of the fees that has been deducted from their account(s). Consequently, all fees are clearly
disclosed. We have a policy prohibiting the charging of any fees in advance. Lower fees than ours for comparable services
may be available from other sources.

CCI’s fees are in addition to any brokerage commissions, transaction fees, and other related costs and expenses which may
be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investments, and
other third parties such as fees charged by brokerage firms, custodial fees, 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. Mutual funds and exchange-traded funds also charge internal management fees, which are disclosed in a
fund’s prospectus. Such charges, fees, and commissions are exclusive of and in addition to our fee, and we do not receive
any portion of these commissions, fees, and costs.

Clients have the option to purchase investment products that we recommend through any broker or dealer of their
choosing. In order to avoid conflicts of interest, neither the firm nor any employee of CCI receives any compensation for
the purchase or sale of any security, mutual fund, or investment product on behalf of clients.

Item 12 further describes the factors that CCI considers in selecting or recommending broker-dealers for client transactions
and determining the reasonableness of their compensation (e.g., commissions).

Item 7 – Types of Clients

CCI provides portfolio management services to individuals, high net worth individuals, corporate pension and profit-sharing
plans, corporate investment accounts, individual retirement accounts, trusts, and estates.

CCI generally requires a minimum account size of $250,000. However, we may accept smaller accounts based on either the
total client relationship or an expectation of positive cash flow to the account.