Granite Capital Management LLC

Fees and Compensation
Granite is compensated for its advisory services according to a fee structure that is based on a
percentage of assets under management. Granite receives no commissions or fees from any
outside source with respect to client accounts. The advisory fee charged by Granite does not
include any service or transactions fees (such as brokerage or trading fees) that may be charged
by custodians, mutual funds, or administrators. Clients will incur brokerage and other
transaction costs in the course of the management of their accounts. For further information
on brokerage practices please refer to the Brokerage Practices section of this brochure.

In general, the percentage of assets under management charged to clients ranges from 0.50%
to 1.50% and varies depending on account size. Fees are paid quarterly in arrears (at the end of
the quarter, for service provided during the quarter) based on the market value of the assets

                                                                   Granite Capital Management, LLC

under management at the end of each quarter. Clients do not pay fees in advance. All fees are
negotiable at Granite’s discretion.

In determining the market value of the assets under management, “market value” includes all
cash, money market balances, and the value of all securities and investments. Some assets, as
mutually agreed upon by Granite and the client, may be excluded from the fee calculation.

Granite generally deducts its fee from the client’s account(s) held at the custodian on a
quarterly basis. Based upon mutual agreement, a client may arrange for separate billing for
advisory fees.

Performance-Based Fees and Side-By-Side Management
As of March 31, 2024, Granite does not manage any assets on a performance-based fee
structure nor do we plan on offering such a fee structure in the future. As a result, we have no
conflicts of interest with regard to “side-by-side management”, where some clients are charged
a performance-based fee and others on a percentage of assets under management.

Types of Clients
Granite generally provides investment advisory service to:

      Individuals
      Pension and profit sharing plans
      Trusts, estates or charitable organizations
      Corporations or other business entities

Granite generally requires a minimum account size of $100,000.

Methods of Analysis, Investment Strategies and Risk of Loss
Granite’s security analysis methods include:

      Fundamental
      Technical
      Credit Analysis
      Flow of Funds

The main sources of information that Granite uses include:

      Research material prepared by others
      Prospectuses, filings with the Securities and Exchange Commission, Offering Statements

                           Form ADV Part 2B: Uniform Application for Investment Adviser Registration

                                                                     Granite Capital Management, LLC

      Financial newspapers, magazines, and websites
      Credit rating services
      Press releases
      Other publicly available information

The investment strategies Granite follows include:

      Long-term purchases (securities held at least a year)
      Short-term purchases (securities sold within a year)
      Margin transactions
      Option writing, including covered options, uncovered options or spreading strategies

       (Essentially all of the strategies Granite follows involve long-term purchases. Other
       strategies are listed here as they could be used to create customized solutions to
       specific investment objectives or situations.)

Investment strategies are implemented in order to achieve a targeted asset allocation for
clients according to their individual circumstances and overall profile. These strategies seek to
gain exposure to various asset classes in a diversified way. Granite continually monitors client
portfolios and rebalances asset allocations when appropriate with sensitivity to keeping costs
low and achieving tax efficiency.

The primary asset classes are equities and fixed income securities. Most often equity exposure
is gained by way of extensively diversified mutual funds that target various market sectors
including US, International and Emerging Markets. Within these sectors, an enhanced exposure
to small capitalization and value stocks is generally targeted. These exposures are sought in an
effort to enhance returns over time, as academic studies have shown that the increased risk
associated with these asset classes has paid investors a higher return over the long term.

Fixed income exposure is generally gained by way of the construction of bond portfolios
comprised of individual securities. If a client’s account does not, in Granite’s judgment, have
enough assets available to construct a reasonably diversified portfolio, fixed income funds will
be used.

Various sectors of the fixed income market are targeted including municipal, corporate,
mortgage-related, and US Treasury securities. Fixed income investments are implemented with
a hold-to-maturity strategy. Investing in fixed income securities involves credit risk (risk of
default or non-payment) and interest rate risk.

For all strategies involved a client should be aware that investing in securities involves risk of
loss that clients should be prepared to bear.

                            Form ADV Part 2B: Uniform Application for Investment Adviser Registration

                                                                     Granite Capital Management, LLC