CCM Partners LP

Item 5: Fees and Compensation
The management fee paid to Shelton Capital Management for separately managed accounts is determined based on each
client’s individual needs and applicable portfolio restrictions and the distribution channel through which the account is
established. The annual management fee is charged as a percentage of assets under management (discretionary and non-
discretionary accounts) or a minimum fee arrangement and may be negotiable in the sole and absolute discretion of Shelton
Capital Management.
The following provides important information concerning the payment of the management fee and its calculation.

Prepayment of Fees
Management fees are normally paid quarterly in advance generally within fifteen (15) business days of the end of the calendar
quarter. The fees are deducted from your account by the custodian.

Refund of Pre-Paid Fees
In the event an account closes prior to the end of a billing period, the pre-paid management fees will be prorated from the
date of closing and credited back to the client.

Basis of Fee Calculation
Management fees are based on net market value of an account as of the close of business on the last day of the calendar quarter.

New Account Establishment During a Quarter
Management fees are calculated based on the value of the assets and prorated for the number of days remaining in the quarter.

Withdrawal of Assets
Assets can be withdrawn generally upon five (5) business days written notice to the Advisor subject to the usual and customary
securities settlement procedures.

Withdrawals or Deposits equal to or greater than $20,000 (cash and/or securities)
The management fee for the balance of the billing period will be prorated as of the date of the transaction to reflect the
withdrawal or deposit and generally will be credited or due at quarter-end following the date of the withdrawal or deposit.

Withdrawals or Deposits less than $20,000 (cash and/or securities)
No fee adjustment will be made during the billing period of the transaction.

Fees received from SMA Strategies
The following management fee schedules are based on which distribution channel establishes the SMA account using Shelton
Capital Management’s investment management services.

                              (800) 955-9988 | www.sheltoncap.com                                                          6

Form ADV, Part 2                                                                                                                       August 3, 2026

                                          Advisor (BD, RIA)                               Solicitor                             Retail Direct
                   Minimum
                                             $100,000                                     $100,000
                  Investment

 Covered ETF                          75 bps — $100K - $250K
  Strategies                   60 bps — Every dollar greater than $250k                Not Applicable
                    Fees                                                                                                         Not Offered
                                  $750 annual minimum per account

                   Minimum
                                              $500,000                                    $500,000
                  Investment

Option Overlay                       60 bps — All dollar amounts                150 bps — All dollar amounts
                    Fees                                                                                                         Not Offered
                                  $3,000 annual minimum per account          $750 annual minimum per account

                   Minimum
                                              $250,000                                    $250,000
                  Investment

Equity Income                                                                    200 bps — $250K - $500K
                                     60 bps — All dollar amounts          150 bps — Every dollar greater than $500k
                    Fees                                                                                                         Not Offered
                                 $1,500 annual minimum per account           $5,000 annual minimum per account

                   Minimum                                                                $250,000
                                              $250,000
                  Investment
 Sustainable
Equity Income
                                     60 bps — All dollar amounts                       Not Applicable                            Not Offered
                    Fees
                                 $1,500 annual minimum per account
                   Minimum                                                             Not Applicable                             $500,000
                                              $250,000
                  Investment
 Corporate
Bond Strategy                                                                                                            99 bps — All dollar amounts
                                     50 bps — All dollar amounts
                    Fees                                                               Not Applicable
                                                                                                                      $4,950 annual minimum per account
                                 $1,250 annual minimum per account

                   Minimum                    $250,000                                 Not Applicable                             $500,000
                  Investment
ESG Corporate
   Bond                              50 bps — All dollar amounts                                                         99 bps — All dollar amounts
                    Fees                                                               Not Applicable
...

Item 7: Types of Clients
Shelton Capital Management provides advisory services to the following types of clients:
  • Individuals (to include high net worth individuals)
  • Pension and profit sharing plan sponsors
  • Pension and profit sharing plan participants

                              (800) 955-9988 | www.sheltoncap.com                                                         10

Form ADV, Part 2                                                                                                August 3, 2026

  • Trusts, Estates, business entities or charitable organizations
  • Nonprofit organizations and other non-governmental organizations
  • Mutual funds
  • State or Municipal governmental entities

Direct Accounts
Direct accounts must execute a written advisory agreement with us before receiving our services.

Sub-Advised Accounts

We may be appointed by other investment management firms to serve as a sub-advisor to one or more accounts managed
by such firms. A written sub-advisory agreement must be executed with us before we begin our sub-advisory services. In
return for sub-advisory services, an investment management firm pays Shelton Capital Management a sub-advisory fee
which generally takes the form of a percentage of the investment management fee received by the investment management
firm. In some cases, Shelton Capital Management may invoice its fees directly to the client’s account for verification and
payment by the custodian if it is the preference of the investment management firm and its client, and is permitted by the
custodian.

Wrap Programs and UMA Programs

We also provide advice to Wrap Clients through broker- sponsored Wrap programs and advise clients in UMA Programs.
In some cases, we provide advice to the sponsor of UMA Programs, rather than the underlying UMA clients. For Wrap
Clients, we generally do not accept new accounts with less than $100,000 in assets, although we may make exceptions to
accommodate the requirements of certain Wrap Sponsors.