Cross Staff Investments Inc

Fees and Compensation – Item 5

Cross Staff Investments, Inc. charges fees based on the type of service that is agreed upon by the
Client and Advisor. Fees for all services may be negotiated by the Firm with the Client and fees
may vary based on a pre-existing relationship, levels of service the Client wants performed,
complexity of the Client’s overall financial situation or based on other unique Client
circumstances. A Client will also be responsible to assume trading charges, such as ticket
charges, maintenance or other account fees as charged by the custodian or Third-Party Money
Manager. Internal mutual fund fees are also an expense that the Client will bear.

For accounts managed by CSI, investment management fees are based on the schedule below and
charged quarterly in arrears. All Clients’ accounts may not be assessed a fee, thus will not be
included in the overall fee calculation. Fees are determined through a discussion between the
Advisor and Client. The Firm will send invoices to Clients on a quarterly basis. Item 12 discusses
additional information regarding assets held in brokerage accounts. Again, this schedule may be
reduced or increased based on a specific situation of a Client, however all fees are based on this
tier and discounted or increased as the Client, Advisor and/or Firm see fit. The Client in all cases
will sign off on the initial fee agreement and will acknowledge a fee change either by signing a
new agreement or receiving a negative consent notice from the Firm of a fee change. This policy
is stated within the Firm’s agreement. However, if the Advisor wishes to charge above 1% the
Firm’s Chief Compliance Officer must approve the fee prior to the signing of the agreement.

The Advisory Fee for accounts held at Schwab and SEI will be charged on a quarterly basis for
services performed in the previous quarter and shall be calculated based on the quarter-ending value
of the account multiplied by the percentage stated with the Advisory, then divided by 4. Using this
calculation, over the course of 4 quarters the Client will have paid the Advisory Fee in an amount
equal to the percentage listed within the Advisory Agreement. Client authorizes and instructs
Advisor and Custodian to deduct the Advisory Fee from the Client’s account as agreed upon in the
Firm’s Advisory Agreement. The Client will be notified of the fee via an invoice that will be sent
to the Client for accounts under management of the Advisor prior to such a fee being deducted from
the accounts. The invoice will include the calculation of such fee. Fees calculated by Third-Party
Money Managers will be shown on the quarterly statement provided by the Third-Party Money
Manager. CSI does not send an invoice for these accounts. Also, CSI does not send invoices for
account held directly at American Funds (Capital Bank & Trust). American Funds charges and
deducts the fee for those accounts in March, June, September, and December. The fee is stated on

January 2026

the statement. Capital Group calculates fees using an average daily assets under management for 3
months prior to the fee deduction and calculates as follows:

Average assets for the quarter x client’s fee rate (.5%) x number of days in quarter
                                 365 (number of days in the year)

The Custodian and transfer agent (Capital Bank & Trust) will perform all valuations of assets in
the account and Advisor will rely on these valuations. In computing the market value of any
security or other investment in the Account, each security listed on a national securities exchange
shall be valued as of the valuation date, generally the last business day of each calendar quarter, at
the closing price on the principal exchange on which it is traded. Any other security or investment
in the Account shall be valued in a manner determined in good faith by the Custodian or, in the
absence of the Custodian’s valuation by a valuation assigned by Advisor to reflect fair market
value. Any valuation shall not be deemed to be a guarantee of any kind by Advisor regarding the
value of the assets in Client’s account. Clients will receive monthly and/or quarterly statements
from the Custodian valuing the investment positions in the account.

All assets held in Client’s account will be subject to the Advisory Fee, including assets, such as
cash, that are temporarily awaiting investment. Client acknowledges that it is Client’s
responsibility to verify the accuracy of the Advisor’s calculation of the Advisory Fee. If there is
not enough liquid cash or equivalents in the account to pay the Advisory Fee when due, the Advisor
may instruct the Custodian to liquidate the necessary positions in the account to cover the amount
due to Advisor. Certain assets, including cash, may be excluded from the fee calculation if
determined by the Advisor and agreed upon with the client. Such exclusion will be noted on the
invoice.

Client will pay transaction fees for execution of trades in the accounts. In addition to the Advisory
Fee, Client will be responsible for all other account fees charged, if any, to the account including
but not limited to costs of trading, safekeeping, custody fees, closeout fees, margin costs (if
applicable. The Firm currently does not utilize margin with client accounts.), and internal mutual
fund fees.

Client understands that services like those provided by Advisor may be available from other sources
at lower costs and under different cost structures that may be beneficial to Client, such as a
brokerage account.

All brokerage commissions, custodial fees, stock transfer fees, transaction fees, charges imposed
directly by mutual, index or exchange-traded funds, fees imposed by variable annuity providers,
certain deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund
fees and other account fees and similar charges incurred in connection with transactions for Client’s
...

Types of Clients – Item 7

We offer investment advisory services as stated above to individuals, trusts, businesses, and
estates.

The Firm currently does not require a minimum account size.

            Methods of Analysis, Investment Strategies and Risk of Loss – Item 8

The Advisors of Cross Staff Investments, Inc. will utilize various methods to manage Client
assets. These methods are based on Client’s individual objectives, risk tolerances as well as their
overall financial condition. The Firm uses traditional methods of researching specific
investments. Use of traditional methods of research does not attempt to anticipate market
movements. This presents a potential risk, as the price of a security can move up or down along
with the overall market regardless of the economic and financial factors considered in evaluating
the stock. Therefore, unforeseen market conditions and/or company developments may result in
significant price fluctuations that can lead to investor losses or gains which can affect a client’s
tax base. The Firm may utilize mutual funds, individual publicly traded securities, exchange
traded funds, Certificates of Deposits and bonds, as well as other cash equivalent holdings in
certain situations. The Firm utilizes software, fund managers and industry specific periodicals
when researching securities for investing.

The Advisors may use a Third-Party Money Manager to assist in the management of the Client’s
investments. Clients always approve of the use of Third-Party Money Managers for use in their
overall financial portfolio. Third-Party Money Management has its own unique risks in investing,
such as additional fees. Also, while the Advisor and Clients can change their portfolios in the
account; neither can buy or sell individual securities held in the portfolio(s) used. This can be a
risk to Clients if they do not wish to be invested in a particular security or group of securities. A
more detailed list of specific risks of each Third-Party Money Manager can be found in their
Form ADV Part 2A that is given to Clients for their review.

January 2026

All investments come with the risk of losing money. Investing in individual securities may carry
significantly more risk than a diversified mutual fund or exchange traded fund. Investing involves
substantial risks, including complete loss of principal plus other losses and may not be suitable
for all individuals. Investments are not insured by the government to protect against market
losses. Clients should be able to assume these types of risks. Different securities carry different
types and degrees of risk and Clients should familiarize themselves with the risks involved in the
securities they intend to invest in. It is important to note that for all investments past performance
is not indicative of future results as many factors weigh on the performance of any particular
investment.

Mutual Funds and Exchange Trade Funds (ETFs) have specific risks aside from those stated
above in that a manager who has been successful may not be able to continue that success in the
future. In addition, the Firm does not control the underlying investments, managers of different
funds held by the client may purchase the same or similar securities, increasing the risk to the
client if that security or sector of securities were to fall in value. There is also risk that the
manager may deviate from the stated investment objective of the fund or ETF, which could make
the fund or ETF less suitable for the Client’s portfolio. Money market mutual funds are not
insured or guaranteed by FDIC or any other governmental agency and may lose money.

With other security types we use there are specific risks to each of them aside from what was
stated above. Equity investments can be volatile and are subject to stock market risk with the
chance that stock prices may decline in value. Stock markets move based on many factors, least
of which is a feeling based on politics, news items, interest rates, etc. The market in its history has
moved in cycles with periods of rising and lowering prices. If you are invested in stocks of
smaller companies, they have a higher probability of failure since they are not as established as
larger capitalized companies. They also may not pay out dividends or capital gains to their
stockholders, as other more established companies may. Bond and interest rates have an inverse
relationship. So, if the price to purchase a bond rises; interest rates are falling. The opposite of
this is also true.