Clinton Investment Management LLC

Fees and Compensation
      CIM provides discretionary investment advisory services on a fee-only basis. CIM is
      compensated for its advisory services by charging a fee that is based on a percentage
      of market value (inclusive of accrued interest) of the assets under management.
      Separately Managed Accounts
      The following table sets forth the Firm’s fee schedule and minimum account size for
      its Separately Managed Accounts that actively seek new clients.

                  Investment                  Fee, Based on Assets Under           Minimum
                    Strategy                    Management (“AUM”)                Account Size

       Municipal Credit Opportunities      0.85% of AUM                           $400,000

                                       0.60% on the first $5 million of
                                       AUM; and
       Municipal Market Duration                                                  $150,000
                                       0.37% on the amount over $5
                                       million of AUM
                                       0.60% on the first $5 million of
                                       AUM; and
       Municipal Intermediate Duration                                            $250,000
                                       0.37% on the amount over $5
                                       million of AUM
                                       0.60% on the first $5 million of
                                       AUM; and
       Municipal Short Duration                                                   $150,000
                                       0.37% on the amount over $5
                                       million of AUM
                                       0.60% on the first $5 million of
                                       AUM; and
       Taxable Market Duration                                                    $150,000
                                       0.37% on the amount over $5
                                       million of AUM

      In certain circumstances, fees and account minimums for separate account
      management may be negotiable. CIM may negotiate alternative fees on a client-by-
      client basis. Client facts, circumstances, and needs are considered in determining the
      fee schedule. Relevant factors in pricing decisions include, but are not limited to,
      whether the account was incepted with CIM via a Wrap Fee Sponsor or Financial
      Adviser, the complexity of the client, assets to be placed under management,
      anticipated future contributions, related accounts from the client or persons related to
      the client, account composition, client-imposed restrictions, and reporting required by
      the client, among other factors.
      The specific annual fee schedule charged by CIM will be identified in the investment
      management agreement between CIM and each client, and/or the governing
      documents of the Wrap Fee Sponsor or Financial Adviser, as applicable. Once CIM
      enters into an investment management agreement with a client, CIM will only modify
      its fee as permitted under that agreement and applicable law.

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      For providing its services in connection with clients referred by Financial Advisers,
      where CIM does not bill the client directly, CIM receives a portion of the fee charged
      by the Financial Adviser to the client.
      For providing its services in connection with Wrap Fee Sponsors, CIM receives a
      portion of the wrap fee charged by the Wrap Fee Sponsor to Wrap Fee Sponsor clients.
      CIM may change its fee structure at any time.
      Unless otherwise stipulated, annual fees for Direct Clients as well as Wrap Fee Sponsor
      and Financial Adviser clients that are dual contract in nature, are calculated and billed
      quarterly, in advance, based upon the market value of the assets on the last business
      day of the previous quarter using third party pricing provided by the custodians.
      Annual fees for Wrap Fee Sponsor and Financial Adviser relationships, that are not
      dual contract in nature, may be calculated and paid either monthly or quarterly in
      advance or arrears depending upon the agreement entered into between CIM and the
      Wrap Fee Sponsor or Financial Advisor.
      Fees on assets deposited or withdrawn for partial quarters will be calculated on a pro-
      rata basis.
      For those clients billed in advance, they will obtain a refund of any pre-paid fees if
      their investment management agreement with CIM is terminated or a withdrawal is
      made from the account before the end of the billing period. CIM will generally
      determine the amount of the relevant refund by pro rating the fee for the number of
      days the assets were managed, based on the value of all assets in the account as of the
      effective date of termination or withdrawal, which will be the next earliest business
      day if the effective date of termination or withdrawal is a non-business day.
      The terms of all fee arrangements are set forth in any investment management
      agreement entered into between CIM and the client, the Wrap Fee Sponsor or the
      Financial Adviser. The investment advisory agreement between CIM and the client,
      the Wrap Fee Sponsor or the Financial Adviser will continue until terminated by
      written notice as detailed in the investment advisory agreement.
      In the case of Direct Clients and some dual contract arrangements, both CIM's
      investment advisory agreement and the client’s custodial/clearing agreement allow the
      custodian to debit the account for the amount of the CIM investment management
      fee and to directly transfer that investment management fee to CIM. In the instance
...

Types of Clients

      The Firm provides (and seeks to provide) investment advice to the following types of
      clients:

          •    Individuals
          •    High net worth individuals
          •    Family Offices
          •    Registered investment companies
          •    Trusts or estates
          •    Corporations and other business entities
          •    Insurance companies
          •    Other investment advisers
          •    Financial Advisers
          •    Broker/Dealers
          •    Banks and trust companies
          •    Wrap Fee Sponsors
      CIM provides its clients with discretionary investment advisory services for each SMA.
      CIM has established a minimum account or investment size for its various products.
      Please see the table under the section “Fees and Compensation.”
      CIM does not guarantee the time period within which an account will be fully invested.
      The amount of time to fully invest a client account will be impacted by a variety of

CLINTON INVESTMENT MANAGEMENT, LLC-Form ADV Part 2A-March 20, 2026                       Page 6

      factors including, but not limited to, the particular investment strategy selected,
      municipal bond specific market conditions at the time of investment (e.g. general
      market liquidity, the volume and amount of new municipal bonds being issued),
      macro-economic conditions at the time of investment, the means by which the
      investment was funded, and the size of the investment. Additionally, the number of
      new client accounts being opened or funded at CIM may impact the time it takes for
      CIM to get any one client’s account fully invested. Although market conditions may
      make it possible for an account to be fully invested within shorter periods of time, it
      can take up to twelve weeks or more to fully invest an account under normal market
      conditions but may be longer during periods of market disruptions, reduced liquidity
      or volatility, or if CIM determines in its sole discretion that additional time is required
      to prudently implement the investment strategy for any one account.
      The liquidation of an account can be similarly impacted by a variety of factors
      including, but not limited to, the particular investment strategy selected for liquidation,
      municipal bond specific market conditions at the time of liquidation (e.g. general
      market liquidity and trading volume), macro-economic conditions at the time of
      liquidation, and the size of the liquidation. Although CIM will seek to liquidate an
      account as expeditiously as possible, considering the foregoing, CIM may, generally,
      require up to two weeks or greater to complete a full or partial liquidation request by
      a client as CIM seeks reasonable opportunities to liquidate various securities but may
      take longer during periods of market disruptions, reduced liquidity or volatility, or if
      CIM determines in its sole discretion that additional time is required to complete the
      requested liquidation. In those instances where a client instructs CIM to liquidate an
      account in full, or in part, at an accelerated pace, the prices obtained from the sale of
      the securities may be impacted negatively resulting in reduced proceeds, particularly
      during periods of market disruptions, reduced liquidity or volatility.
      The factors impacting either the investment of funds or full or partial liquidation of a
      portfolio can result in an account’s performance deviating from other accounts
      investing in the same strategy.
      For clients who fund their investment in-kind with existing securities, CIM may, in its
      sole discretion, reject any or all such securities.

          Methods of Analysis, Investment Strategies and Risk of Loss

      This section contains a general discussion regarding CIM’s investment philosophy and
      process employed by the Firm and the material risks of investing in the various Firm
      strategies.