Cullen Investment Group Ltd

Item 5 ‒ Fees and Compensation

A. Advisory Fee Structure

1. Investment Management Services

We charge an annual fee based on a percentage of assets under management according to the blended fee
schedule:

           Assets Under Management                                  Annualized Fee %

                   First $1,000,000                                         1.00%

                   Next $4,000,000                                          0.75%

                  Next $15,000,000                                          0.50%

                  Over $20,000,000                                        Negotiable

Under this blended or graduated fee schedule, each tier of assets is charged the corresponding fee
percentage. For example, client assets valued at $7,000,000 would be charged as charged as follows:

    •   First $1,000,000 at 1.00% = $10,000
    •   Next $4,000,000 at 0.75% = $30,000
    •   Next $2,000,000 at 0.50% = $10,000

Total annual fee = $50,000 (0.714% blended rate)

The minimum account size is generally $500,000, which may be met by aggregating Investment
Management Services accounts within the same household. We may accept smaller accounts at our
discretion. Our standard fee schedule may be negotiable based on factors such as account size and service
requirements. Pre-existing advisory clients may be subject to different fee arrangements based on the
terms in effect when they entered into their advisory relationship.

2. Cash Management Services

For Cash Management Services (“CMS”), the Firm charges a flat annual fee of 0.25% on all assets in
each Cash Management Services account.

While CMS does not require a minimum account size, this service is only available to existing Investment
Management Service clients. Our standard fee of 0.25% may be negotiable based on factors including
account size and service requirements. Pre-existing advisory clients may be subject to different fee
arrangements based on the terms in effect when they entered into their advisory relationship.

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3. 401(K) Plan Consulting Services

For 401(k) Plan Consulting Services, the Firm charges an annual fee of 0.25% of plan assets.

B. Fee Billing and Method of Payment

For Investment Management Services and Cash Management Services, we bill advisory fees quarterly in
advance based on the account's market value at the end of the previous calendar quarter. For new
accounts, we prorate the fee for the remainder of the current quarter based on the initial account value.
Asset flows during the quarter resulting in a fee adjustment (credit or debit) over $100 will be reflected on
the following quarter's bill. Fees are typically deducted directly from client accounts the next business day
after billing.

For 401(k) Plan Consulting Services, fees are billed in advance based on the plan’s market value at the
end of the previous calendar quarter. Fees are deducted directly from participant accounts by the plan’s
custodian.

C. Other Fees and Expenses

Clients pay additional fees and expenses beyond our advisory fees, including:

    •   Custodial and brokerage fees (transaction fees, annual IRA fees, account closure fees)
    •   Mutual fund expense ratios (management fees charged by mutual fund companies

Please see Item 12 (Brokerage Practices) for additional information about brokerage fees.

D. Advance Payment Refunds

Clients may terminate their investment advisory agreement at any time by providing written notice. Upon
termination, we will refund the prorated portion of any prepaid fees for the remainder of the quarter.

E. Additional Compensation

Neither Cullen nor any supervised persons accept compensation for the sale of securities or other
investment products.

Item 7 ‒ Types of Clients
Cullen offers its advisory services to individuals, high-net-worth individuals, trusts, estates, charitable
organizations, qualified plan sponsors, and other business entities. For information about our minimum
account-sized requirements, please see "Item 5 – Fees and Compensation."

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