GFG Capital LLC

Item 5 – Fees and Compensation

Investment Management Fees

Non-Discretionary Investment Management and Administrative Services

GFG Capital charges fees for non-discretionary investment management services and
administrative services as a sub-advisor to clients of a third-party investment adviser in accordance
with the fee schedules set forth in the applicable governing agreements among GFG Capital, the
third-party investment adviser and each applicable client. The fees borne by each client are based
on the specific services selected for each client by the third-party investment adviser and are
calculated based on the gross market value of client accounts and accrue on a monthly basis in
arrears.

General Information on Fees

All fees are subject to negotiation.

All fees and the specific manner in which fees are charged by GFG Capital are established in the
client’s investment management agreement with GFG Capital. Clients can either receive an
invoice for the services provided by GFG Capital or give permission to GFG Capital to debit their
account for the relevant amount of fees due. Pursuant to the investment management agreement,
clients’ fees generally will be directly debited from the client accounts at their custodian. With
respect to GFG Capital acting as a sub-adviser to a third-party investment adviser, GFG Capital
generally is paid by the third-party investment adviser.

GFG Capital’s fees are exclusive of brokerage commissions, transaction fees, and other related
costs and expenses which shall be incurred by the client. Clients will incur certain charges imposed
by custodians, brokers, third party investment and other third parties such as fees charged by
managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer
and electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions. Separately managed strategies, mutual funds, and exchange traded funds also charge
internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and
commissions are exclusive of and in addition to GFG Capital’s fee, and GFG Capital does not
receive any portion of these commissions, fees, and costs. 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 and marketing fee (12b-1 fee). GFG Capital and its affiliates
do not receive any 12b-1 fees in relation to mutual funds within accounts managed by GFG Capital.
Similarly, the hiring of Independent Managers will result in additional management and/or
administrative fees by these entities. Clients should review the fees of Independent Managers to
understand completely the total fees paid by the client.

Item 12 further describes the factors that GFG Capital considers in selecting or recommending
broker-dealers for client transactions and determining the reasonableness of their compensation
(e.g., commissions).

A client investment management agreement may be canceled at any time, by either party, for any
reason upon receipt of sufficient advance written notice. Upon termination of an investment
management agreement for any account, any prepaid, unearned fees will be promptly refunded,
and any earned, unpaid fees will be due and payable. The client has the right to terminate an
investment management agreement without penalty within five business days after entering into
the investment management agreement.

Clients should note that similar advisory services may be available from other registered
investment advisers for similar or lower fees. GFG Capital will establish fee relationships with
each client at the start of the advisory relationship.

Other Forms of Compensation We Receive

Custodians provide GFG Capital with electronic systems that assist in the management of GFG
Capital client accounts. Custodians of client accounts may further provide access to research, the
ability to directly debit client fees, software and other technology that provide access to client

account data (such as trade confirmations and account statements), facilitate trade execution (and
allocation of aggregated trade orders for multiple client accounts), pricing information and other
market data, assist with back-office functions, recordkeeping and client reporting.

In exchange for maintaining a certain threshold of assets with Folio Investments, Inc. d/b/a
Goldman Sachs Custody Solutions (“GSCS”), GSCS makes available to GFG Capital transition
services that benefit GFG Capital but might not benefit its clients’ accounts. The transition
assistance can be applied toward qualifying third-party service provider expenses incurred in
relation to transition costs associated with moving client accounts. Receipt of transaction
assistance creates a conflict of interest in our recommending clients use GSCS to custody their
assets. To mitigate this conflict, we have evaluated GSCS’s full suite of services and recommend
the use of GSCS based on the overall value of such services. Additionally, the principals of GFG
Capital will be provided custodial fee waivers for their personal custodial accounts when GFG
Capital clients maintain their accounts at GSCS.

Item 7 – Types of Clients

GFG Capital provides portfolio management services to individuals, high net worth individuals,
pooled investment vehicles, pension and profit-sharing plans, corporations third party asset
managers and insurance companies.