Garrett Nagle & Co Inc

Item 5       Fees and Compensation

                 PORTFOLIO MANAGEMENT SERVICE FEES
Our annual fees for portfolio management services are based upon a percentage
of assets under management and generally range from 1.0% to 1.5%. However,
see the “Prepayment of Fees” subsection of this Item 5 where under certain
circumstances an advisory fee may exceed the client’s agreed upon advisory fee
after the client makes a partial withdrawal from an advisory account.

The annualized fee for Portfolio Management Services is charged as a percentage
of assets under management, according to the following schedule:

Assets Under Management                                                 Annual Fee
       First $1,000,000                                                      1.5%

            In Excess                                                    Negotiable

A minimum of $500,000 of assets under management is required for this service.
This account size may be negotiable under certain circumstances. Garrett Nagle &
Co., Inc. may group certain related client accounts for the purposes of achieving
the minimum account size and determining the annualized fee.

Limited Negotiability of Advisory Fees: Although Garrett Nagle & Co., Inc. has
established the aforementioned fee schedule(s), we retain the discretion to
negotiate alternative fees on a client-by-client basis. Client facts, circumstances
and needs are considered in determining the fee schedule. These include the

complexity of the client, assets to be placed under management, anticipated
future additional assets; related accounts; portfolio style, account composition,
reports, among other factors. The specific annual fee schedule is identified in the
contract between Garrett Nagle & Co., Inc. and each client.

Discounts not generally available to our advisory clients, may be offered to family
members and friends of associated persons of our firm.

Other Revenue
Garrett Nagle & Co., Inc. is also registered with the Securities and Exchange
Commission (“SEC”) as a broker-dealer and is also a FINRA member.
Management personnel and other related persons of our firm are licensed as
registered representatives of the broker-dealer and, acting in that capacity, they
can implement transactions for our advisory clients. We have an introducing-
clearing arrangement with National Financial Services, LLC (“NFS”) to clear the
brokerage transactions we introduce on behalf of investment advisory clients.
Under this arrangement, NFS allows us to keep a portion of the commissions
generated on the transactions cleared through NFS provided NFS earns on such
commissions at least $5,000 per month based on its internal fee schedule.
Consequently, Garrett Nagle & Co., Inc. receives both an advisory fee and
commissions for managing advisory client accounts whose brokerage transactions
clear through NFS. The total of these separate charges may be greater than
expenses a client would incur with other options. Commissions represent
approximately a quarter of Garrett Nagle & Co., Inc.’s annual revenue. Therefore,
we have an incentive to generate commissions on behalf of our clients.
Nevertheless, notwithstanding this potential conflict of interest, it is our policy to
trade for you in a manner that we believe to be in your best interests.

The amount of commissions paid to Garrett Nagle & Co. by clients is subject to
negotiation and certain clients pay higher brokerage commissions than other
clients.

                          GENERAL INFORMATION
Termination of the Advisory Relationship: A client agreement may be
canceled at any time, by either party, for any reason upon receipt of 7 days
written notice. As disclosed above, certain fees are paid in advance of services
provided. Upon termination of any account, any prepaid, unearned fees will be
promptly refunded. In calculating a client’s reimbursement of fees, we will pro
rate the reimbursement according to the balance remaining in the billing period.

Mutual Fund Fees: All fees paid to Garrett Nagle & Co., Inc. for investment
advisory services are separate and distinct from the fees and expenses charged by
mutual funds and/or ETFs to their shareholders. These fees and expenses are
described in each fund’s prospectus. These fees will generally include a
management fee, other fund expenses, and a possible distribution fee. A client
could invest in a mutual fund directly, without our services. In that case, the client
would not receive the services provided by our firm which are designed, among
other things, to assist the client in determining which mutual fund or funds are
most appropriate to each client’s financial condition and objectives. Accordingly,
the client should review both the fees charged by the funds and our fees to fully
understand the total amount of fees to be paid by the client and to thereby
evaluate the advisory services being provided. Garrett Nagle & Co., Inc. does not
actively purchase funds with front or back-end loads or with 12b-1 fees.

Separately Managed Account Fees: Some Garrett Nagle & Co., Inc clients
pay a single fee for advisory, brokerage and custodial services. Clients’ portfolio
transactions may be executed without commission costs in this arrangement. In
evaluating such an arrangement, the client should also consider that, depending
upon the level of fee charged, the amount of portfolio activity in the client’s
account, and other factors, the fee may or may not exceed the aggregate cost of
such services if they were to be provided separately.

Additional Fees and Expenses: In addition to our advisory fees, clients are
also responsible for transaction charges. Please refer to the “Other Revenue”

subsection of this Item 5 above and the “Brokerage Practices” section (Item 12) of
this Form ADV for additional information.

Grandfathering of Minimum Account Requirements: Pre-existing advisory
clients are subject of Garrett Nagle & Co., Inc.’s minimum account requirements
...

Item 7       Types of Clients

Garrett Nagle & Co., Inc. provides advisory services to the following types of high-
net-worth clients:

Types of Client               Assets as of 12/31/25                # of Accounts
Individual Accounts                 $26,779,229                        48

IRA’s                               $39,508,141                        60

Trusts                              $25,943,947                        34

Corporations                        $6,127,504                          2