Finiat LLC

Item 5 – Fees and Compensation

Technology Platform Services

FINIAT generally charges a technology user fee to permit institutional investors to use the
Portal and receive instructions from our supervised persons. Additional fees are imposed
whereas the number of users exceeds certain thresholds as set forth in the applicable
agreement. Fees are negotiable but generally start

Strategy Consulting Services

FINIAT generally charges an asset-based fee commensurate with the assets under
advisement (AUA) for which our Firm furnishes investment consulting services. Additionally,
an incentive fee may be imposed whereas the portfolios for which we provide AUA reach or
surpass a performance level as set forth in the underlying agreement.

Investment Management Services

FINIAT offers Investment Management Services an advisory service for institutional clients
in exchange for the terms of compensation specified in the IMA. Fees vary based on the
complexity and scope of services facilitated. Fees are assessed as a percentage of the assets
under management (“AUM”) for the product or service offerings for which the portfolio
model(s)/signals are supplied for our institutional clients and are typically set in a tiered
structure within each consulting agreement. Another component of the overall management
fee is based upon the sophistication of the technology and the frequency of the investment
signals required to exercise the client’s portfolio models. Fees are negotiable and typically
range from 101 basis points (.10%) to 200 basis points (2.00%) of AUM plus, where attained,
an additional 20% of underlying account profits where our Firm has achieved the incentive
fee established under the agreement. For additional information, refer to Item 6. FINIAT’s
IMAs do not include terms or conditions related to technology user fees or licensing fees and
are strictly limited to fees applicable to the advisory services rendered on behalf of our
institutional clients.

Additional Fees and Expenses

Fees other than the asset-based fees discussed above may be imposed by FINIAT including
technology fees, platform fees or user fees (together “Other Fees”). These Other Fees will be
contingent upon the individualized platform or service offerings and shall be disclosed in the
written agreement between FINIAT and the client (or other interested entity where a tri-
party is required). Certain investment offerings including ETFs could impose a 12b-1 fee and
typically an alternative share class available for the ETF is not applicable. Investors in
portfolios that investment in ETFs subject to 12b-1 fees will pay that charge indirectly to the
ETF sponsor in addition to the management fee and other administrative costs as outlined in
the prospectus.

Custodian, Trading, and Other Costs

All fees paid to FINIAT for investment advisory services (whether primary investment
adviser or sub-adviser) are separate and distinct from transaction fees charged by RIAs, Wrap
Program Sponsors, ETF Managers and broker-dealers associated with the purchase and sale
of equity securities and options. Other fees charged to investors in addition to the Firm’s

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management fee (which may be inclusive of the Sub-Adviser’s fee) include transaction fees,
deferred sales charges, wire transfer fees, documentation preparation fees, operating
expenses for the registered investment companies or other pooled investment vehicles
offering(s), acquired fund fees and expenses. Moreover, management fees do not generally
include the services of any co­fiduciaries, accountants, broker dealers or attorneys that may
be engaged.

Termination and Refunds

FINIAT does not deduct consulting fees, investment management fees, or
incentive/performance-based fees, directly from its clients or accounts managed by its
clients. Clients may terminate their agreement with our Firm under the applicable terms and
provisions of the IMA. Clients are invoiced by FINIAT under the terms of the IMA; however,
our Firm will provide a refund where subject under such agreements which generally
required 30 days advanced notice in writing from our clients.

Payment of Fees

FINIAT does not deduct any fees directly from its clients but will transmit an invoice in
accordance with the terms and provision of the applicable contractual agreement. As such,
fees owed to FINIAT by our clients may be paid in advance or arrears and on either a monthly
or quarterly basis.

Important Additional Information

FINIAT, in its sole and absolute discretion, retains the right to modify fees paid by clients
subject to proper notification in writing and in advance of 30 days. In addition, the fees
assessed by FINIAT in exchange for the advisory services it renders is determined on a
client­by­client basis which includes, among other, the size, complexity and nature of the
advisory services provided. As a general standard, FINIAT retains the fees outlined in the IMA
without material changes made except in extraordinary circumstances such as a substantial
increase or decrease in assets managed or implementation of more complex investment
strategy.

Item 7 – Types of Clients

FINIAT provides advisory services (as specified in Item 4) through an IMAwith other financial
institutions, including TAMPs, insurance companies, registered investment advisers,
collective investment trusts (, hedge funds, pooled investment vehicles, and registered
investment companies. FINIAT does not provide customized investment advice to
individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates, or
charitable organizations; however, such investors typically invest in the SMAs or Wrap
Programs offered by FINIAT’s institutional clients directly.

Engaging the Services of FINIAT

All financial institutions, including SEC and state­registered investment advisers, must
generally enter into a written agreement with FINIAT that memorializes applicable fee
arrangements, user rights to access our Firm’s Portal, and other pertinent items.

Conditions for Advising Clients

FINIAT does not open advisory accounts for our Firm’s clients or on behalf of clients
underlying investors’ accounts. FINIAT relies upon the client to open advisory services or
establish product offerings (e.g., ETFs) for which our Firm then provides the selected
advisory services. FINIAT does not require a minimum account size for which it will provide
advisory services nor does our Firm mandate a minimum dollar amount in advisory fees per
annum; however, our Firm’s clients may otherwise impose a minimum account size or dollar
amount in advisory fees to their investors, FINIAT reserves the right to refuse any client
engagement for any reason at its sole discretion.