Gladstone Institutional Advisory LLC

Item 5. Fees and Compensation

Investment Management Fees

Gladstone charges an annual advisory fee of up to 2.00% of assets under management for investment
advisory services. Fees are assessed on all asset types, including securities, cash, and cash equivalents,
and are generally billed quarterly in advance. Advisory fees are negotiable and established in writing prior
to the commencement of services through an investment management agreement, billing agreement, or
applicable custodian or carrier documentation.

The advisory fee negotiated with your representative may differ from fees charged to other clients or by
other representatives based on factors such as account size, complexity, scope of services, and other
relevant considerations. Because higher advisory fees increase compensation to both the representative
and Gladstone, this presents a conflict of interest.

In non‑wrap programs, clients pay advisory fees separately from brokerage commissions, transaction
costs, and other execution‑related expenses. In wrap fee programs, most transaction costs are bundled into
a single asset‑based fee; however, clients may still incur certain additional expenses. In
Gladstone‑sponsored wrap programs, representatives pay an asset‑based pricing fee to the custodian to
cover transaction costs, whereas clients in non‑wrap programs pay such charges directly. This creates a
conflict of interest, as representatives may have a financial incentive to recommend non‑wrap accounts
even when clients may incur higher overall costs. See Item 10 for more information about asset-based
pricing.

Clients should understand that advisory fees may exceed comparable broker‑dealer commission costs
during periods of limited trading activity. Clients are not required to implement investment
recommendations through Gladstone or its representatives and may do so through unaffiliated brokers or
agents.

Advisory fees for certain programs can be structured utilizing a flat asset-based fee or on tiered fee
basis, with a reduced percentage rate based on the account reaching certain thresholds. Depending on
the program and custodian, clients can designate specific positions held at approved custodians as
unbillable, meaning those positions are excluded from fee calculations. Gladstone does not monitor,
supervise, or provide advisory services with respect to unbillable positions.

Except for annuities linked to LPL SWM accounts, advisory fees for annuities are billed directly by the

insurance issuer and may follow a billing cycle different from Gladstone’s standard quarterly billing
practices.

Either Gladstone or the client may terminate the advisory agreement at any time. Upon termination, clients
receive a prorated refund of any unearned prepaid advisory fees based on the number of days remaining
in the billing period, subject to applicable custodian or platform terms. Clients are responsible for
monitoring their accounts following termination and may incur commissions or other transaction‑related
charges in addition to advisory fees.

Fees are assessed on all asset types, including securities, cash, and cash equivalents, and are billed
quarterly in advance. Fees for the initial quarter are adjusted pro rata based upon the number of calendar
days in the quarter that the Investment Advisory Agreement goes into effect. Payment of fees may result
in the liquidation of a client’s securities if there is insufficient cash in the account.

If assets are deposited into or withdrawn from an account after inception of a billing period in an amount
equal to or greater than $5,000, the fee payable with respect to such assets is prorated to reflect the
change in portfolio value.

In non-wrap programs, clients pay advisory fees separately from brokerage commissions, transaction
charges, and other execution-related expenses. In wrap fee programs, most transaction costs are bundled
into a single asset-based fee; however, clients may still incur certain additional expenses, such as
custodial fees, step-out charges, and underlying investment product expenses. Whether a wrap or
non-wrap program is more cost-effective depends on factors such as trading activity, services provided,
and overall account structure.

Except for annuities linked to LPL SWM accounts, advisory fees for annuities are billed directly by the
insurance issuer and may follow a billing cycle different from Gladstone’s standard billing practices.

In wrap programs, representatives pay an asset-based pricing fee to the custodian to cover transaction
costs, whereas clients in non-wrap programs pay transaction charges directly. This creates a conflict of
interest, as representatives have a financial incentive to recommend non-wrap accounts even when
clients may incur higher overall costs.

Fees are calculated based on asset values reported by the qualified custodian. Gladstone does not
participate in or adjust these valuations. Payment of fees may result in the liquidation of securities if
insufficient cash is available.

Advisory agreements may be terminated by either party upon written notice. Upon termination, clients
receive a prorated refund of any unearned prepaid advisory fees based on the number of days remaining
in the billing period, subject to applicable custodian or platform terms. Clients are responsible for
monitoring their accounts following termination and may incur commissions or other transaction-related
charges in addition to advisory fees.

Qualified Retirement Plan Fees:

We charge an asset-based advisory fee for investment management services, including accounts accessed

via third-party technology platforms. This fee is based on a percentage of assets under management and
is detailed in your investment advisory agreement. Fees are billed either monthly or quarterly, in advance
or arrears, as specified in your agreement.

We use third-party technology platforms to access and manage held-away accounts. Each third-party
...

Item 7. Account Requirements and Types of Clients

Gladstone’s service offerings currently extend to individuals, high net worth individuals, trusts,
corporations, businesses, pension and profit-sharing plans, and charitable organizations. Gladstone
requires a minimum initial investment of $0 to $100,000, depending on the program or third-party money
manager utilized. Gladstone and the third-party money manager (if any) can waive minimum initial
investment requirements at its discretion.