Chiron Capital Management LLC

ITEM 5 – FEES AND COMPENSATION

Chiron offers services on a fee basis, which may include fixed as well as fees based upon assets under
management or advisement.

Wealth Management Fees

The Firm offers investment management for an annual fee based on the amount of assets under
management. This management fee generally varies between 50 and 150 basis points (0.50% -
1.50%), depending on the size and composition of a client’s portfolio and the type of services rendered.

The annual fee is prorated and charged quarterly, in advance, based upon the market value of the
assets being managed by the Firm on the last day of the previous billing period.

If assets in excess of $10,000 are deposited into or withdrawn from an account after the inception
of a billing period, the fee payable with respect to such assets is adjusted to reflect the interim change in
portfolio value. For the initial period of an engagement, the fee is calculated on a pro rata basis. In
the event the advisory agreement is terminated, the fee for the final billing period is prorated through
the effective date of the termination, and the outstanding or unearned portion of the fee is charged or
refunded to the client, as appropriate.

Additionally, for asset management services the Firm provides with respect to certain client holdings
(e.g., held-away assets, accommodation accounts, alternative investments, etc.), the Firm may
negotiate a fee rate that differs from the range set forth above.

Fees for Participation in the Wrap Fee Program

A portion of the fees paid to the Firm is used to cover the securities brokerage commissions and
transactional costs attributed to the management of its clients’ portfolios. These fees are
referenced in the previous section, Wealth Management Fees.

Services provided through the Program may cost clients more or less than purchasing these
services, wealth management, and brokerage commissions/transactional services separately. The
number of transactions made in clients’ accounts, as well as the commissions charged for each
transaction, determines the relative cost of the Program versus paying for execution on a per
transaction basis and paying a separate fee for advisory services. Therefore, the Firm has an incentive

Chiron Capital Management, LLC                                                            January 1, 2026 – v1

to place fewer trades for clients in the Program since the Firm incurs transaction expenses. Fees paid
for the Program may also be higher or lower than fees charged by other sponsors of comparable
investment advisory programs.

Fee Discretion

The Firm may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such
as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets
to be managed, related accounts, account composition, pre-existing/legacy client relationship,
account retention, and pro bono activities.

Additional Fees and Expenses

In addition to the advisory fees paid to the Firm, clients may also incur certain charges imposed by
other third parties, such as broker-dealers, custodians, trust companies, banks and other financial
institutions (collectively “Financial Institutions”). These additional charges may include custodial
fees, fees attributable to alternative assets, reporting charges, margin costs, charges imposed directly
by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund
management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer
taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts. The
Firm’s brokerage practices are described at length in Item 12, below.

Direct Fee Debit

Clients generally provide the Firm with the authority to directly debit their accounts for payment of
the investment advisory fees. The Financial Institutions that act as the qualified custodian for client
accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send
statements to clients not less than quarterly detailing all account transactions, including any amounts
paid to the Firm.

Account Additions and Withdrawals

Clients may make additions to and withdrawals from their accounts at any time, subject to the Firm’s
right to terminate an account. Additions may be in cash or securities, provided that the Firm reserves
the right to liquidate any transferred securities or declines to accept particular securities into a client’s
account. Clients may withdraw account assets on notice to the Firm, subject to the usual and customary
securities settlement procedures. However, the Firm generally designs its portfolios as long-term
investments, and the withdrawal of assets may impair the achievement of a client’s investment
objectives. The Firm may consult with its clients about the options and implications of transferring
securities. Clients are advised that when transferred securities are liquidated, they may be subject to
transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent
deferred sales charges), and/or tax ramifications.

Chiron Capital Management, LLC                                                            January 1, 2026 – v1

ITEM 7 – TYPES OF CLIENTS
Chiron offers investment advice to individuals, pension and profit-sharing plans, trusts, estates,
charitable organizations, corporations, and other business entities.

Minimum Account Requirements

The Firm does not impose a stated minimum fee or minimum portfolio value for starting and
maintaining an investment management relationship.