Glass Lakes Capital Management LLC

Item 5 - Fees and Compensation
    Forms of payment are based on the types of services being provided, terms of service, etc., and will be
    stated in your engagement agreement with our firm. Our published fees are negotiable, and we typically
    waive or discount our fee for associates of our advisory firm and their family members. We strive to offer
    fees that are fair and reasonable in light of the experience of our firm and the services to be provided to
    you. Comparable services may be provided by other advisers, potentially for a lower fee.

    Financial Planning and Education Workshops
    We believe every client should have a basic knowledge and understanding of their goals and objectives, as
    well as a foundation -- a plan. As such, we do not charge a fee for our educational workshops or financial
    planning sessions, whether your plan is broad-based or narrowly focused.

    Portfolio Management Services
    We do not require a minimum account size to open and maintain an investment account, nor do we assess
    account opening and/or administration fees to initiate our portfolio management services. For the benefit of
    discounting our asset-based fee, we will aggregate accounts within the same household unless instructed by
    the client not to do so. We assess an annualized asset-based fee for our services up to 1.50% (150 basis
    points) depending on account size, advisory services required, and as agreed with you in advance. One basis
    point equals 1/100 of one percent. The advisory fee is paid to our firm quarterly, in advance or in arrears per
    the engagement agreement, and will be based on the account’s value each billing period as calculated using
    the following formula: (quarterly account market value) x (applicable number of basis points) ÷ 4 (quarters).

    Example: A portfolio management account maintaining $1,000,000 of investible assets being assessed a one
    percent asset-based fee will pay a quarterly fee of $2,500. Formula: ($1,000,000 x 100 bps) = $10,000
    (annualized fee) ÷ 4 (quarters) = $2,500 (quarterly fee).

2   The term “assets under management” and rounding per the SEC’s General Instructions for Part 2 of Form ADV.

    Glass Lakes Capital Management LLC
    Form ADV Part 2 – 20260521 SEC

    In the rare absence of a reportable market value, our firm may seek a third-party opinion from a recognized
    industry source (e.g., unaffiliated public accounting firm), and the client may choose to separately seek such
    an opinion at their own expense as to the valuation of “hard-to-price” securities if they believe it to be
    necessary.

    The firm does not bill accounts off-cycle; we only bill on a quarterly basis. Therefore, on any deposits or
    withdrawals exceeding $50,000 per day we will credit or debit the account for partial periods on a prorated
    basis during the following quarter’s billing cycle. Fee payments will generally be assessed within the first 15
    calendar days of each billing cycle. Your written authorization is required in order for the custodian of record
    to deduct our advisory fee from your account. By signing our firm’s engagement agreement, as well as the
    custodian account opening documents, you will be authorizing the custodian to withdraw both advisory fees
    and any transactional fees from your account. The custodian will remit our fees directly to our firm.

    Fees deducted from your account will be noted on statements that you will receive directly from your
    custodian of record.3 We encourage you to verify the accuracy of fee calculations; the custodian may not
    verify the accuracy of advisory fee assessments for each account or on a consistent basis. Alternatively, you
    may request to directly pay our advisory firm its portfolio management fee in lieu of having the advisory fee
    withdrawn from your investment account. A client’s direct payment must be received by our firm within 15
    days of our invoice.4 Our firm does not accept cash, money orders or similar forms of payment for its
    engagements.

    Third-Party Investment Management
    Each third-party investment manager program has a stated fee range that will be described using that
    investment manager’s disclosure documents and prior to the selection of the investment manager. The
    third-party investment manager’s annualized asset-based fee ranges from 0.10% to 0.75% (10 to 75 basis
    points); paid in advance or arrears per the selected investment manager’s disclosure. The third-party
    investment manager’s fee is separate from our advisory fee and is billed separately from ours.5

    Additional Client Fees
    Any transactional or service fees (sometimes termed brokerage fees), individual retirement account fees,
    qualified retirement plan fees, account termination fees, or wire transfer fees will be borne by the account
    holder per the custodian of record’s separate fee schedule. We will provide you with a copy of our
    custodian’s fee schedule at the beginning of the engagement, and you will be notified of any future changes
    to those fees by the custodian of record and/or third-party administrator for certain tax-qualified plans.
    Additional information about our fees in relationship to our “brokerage” practices is noted in Item 12 of this
    document.

    Fees paid by our clients to our firm for our advisory services are separate from any internal fees or charges a
    client may pay for mutual funds, exchange-traded funds (ETFs), exchange-traded notes (ETNs), or other
    similar investments.

    If a sub-adviser or model portfolio is used within your account, the fee assessed (in addition to our advisory
    fee) will range from 0.01% to 0.75% (1 to 75 bps).5

3 Periodic account value variances between the firm’s invoice and custodian statement (beyond the firm’s control) may occur due to
...

Item 7 - Types of Clients
Glass Lakes Capital Management LLC provides its services to individuals, high net worth individuals, and
charitable organizations. Our firm does not require minimum income, asset levels or other similar
preconditions noted in this document. We will inform you in advance of any minimum criteria should a sub-

Glass Lakes Capital Management LLC
Form ADV Part 2 – 20260521 SEC

adviser or third-party investment manager be engaged. We have established a minimum account size of
$50,000 for our wrap program which is described in further detail in our separate wrap fee program
brochure.