Gurtin Fixed Income Management LLC

Fees and Compensation

Description and Fee Schedule
Gurtin receives management fees from the client based upon a percentage of the client’s assets under
management no more than what is outlined below:

Intermediary Firm Clients

 Strategies with Flat Fee Schedule Aggregated by Intermediary Firm Assets*
                                     Account       Up to       $25 to     $50 to       $100 to   $500MM     Above
   Strategy
                                     Minimum      $25MM       $50MM      $100MM       $500MM      to $1B     $1B
   Municipal Ultra Short               $1MM        13 bps     13 bps         12 bps    10 bps     9 bps     8 bps

   Municipal Ladders                   $250K       13 bps     13 bps         12 bps    10 bps     9 bps     8 bps

   Municipal Intermediate Value        $500K       30 bps     25 bps     22.5 bps      20 bps    17.5 bps   15 bps

   Municipal Extended Value            $500K       30 bps     25 bps     22.5 bps      20 bps    17.5 bps   15 bps

   Municipal Defeasement               $1MM        10 bps     10 bps         10 bps    10 bps     9 bps     8 bps

   Municipal Tax Liability             $1MM        6 bps       6 bps         6 bps     6 bps      6 bps     6 bps

   Government Ladders                  $1MM        12 bps     12 bps         10 bps    8 bps      7 bps     5 bps

   Government Defeasement              $1MM        8 bps       8 bps         8 bps     8 bps      7 bps     5 bps

Form ADV Part 2A Annual Amendment March 31, 2022

      Government Tax Liability            $1MM         4 bps      4 bps       4 bps     4 bps      4 bps      4 bps

    Strategies with Blended Fee Schedule Aggregated by Client Family Group
                                        Account        First      $5 to       $10 to    $50 to     Above
      Strategy
                                        Minimum       $5MM       $10MM       $50MM     $100MM     $100MM
      Municipal Stability                 $1MM        25 bps     20 bps      15 bps     12 bps    12 bps

      Government Cash Management          $250K       10 bps     10 bps       8 bps     6 bps      6 bps

      Government Enhanced Liquidity       $1MM        15 bps     12 bps      11 bps     10 bps    10 bps

    Strategies with Flat Fee Schedule Aggregated by Client Family Group
                                        Account       Up to       $5 to       $10 to    $50 to     Above
      Strategy
                                        Minimum       $5MM       $10MM       $50MM     $100MM     $100MM
      Municipal Opportunistic Value       $2MM        45 bps     35 bps      25 bps    22.5 bps   20 bps

*   Subject to PIMCO’s approval, assets may be aggregated at the Intermediary Firm level when determining
    the fees payable under this Agreement including certain Intermediary client assets invested in
    investment vehicles, products or accounts for which PIMCO serves as manager (“Total Relationship
    Aggregation Size”). Certain Intermediary client assets will not be eligible to be included in Total
    Relationship Aggregation Size, such as closed-end fund, exchange-traded fund and sub-advised products
    or other account assets that are managed by PIMCO or its affiliates that cannot be readily identified as
    Intermediary client assets by PIMCO or its affiliates, or assets attributable to a defined contribution plan
    or assets otherwise determined to be ineligible for aggregation by PIMCO or its affiliates in their
    discretion due to legal, regulatory or other restrictions. The Total Relationship Aggregation Size of an
    individual Intermediary is determined by PIMCO in its sole discretion. Neither PIMCO nor any of its
    affiliates shall be responsible for any miscalculation of the Total Relationship Aggregation Size, nor
    obligated to reimburse any fees received due to a miscalculation of the Total Relationship Aggregation
    Size. In the event PIMCO or Gurtin determines at the end of a quarter that the Total Relationship
    Aggregation Size is either no longer eligible for a fee reduction or eligible for a smaller fee reduction,
    the higher fee rate will apply effective immediately with respect to that billing quarter and any
    subsequent billing quarters as applicable.

Direct Clients
    Strategies with Flat Fee Schedule Aggregated by Client Family Group
                                        Account       Up to       $5 to       $10 to    $25 to     $50 to     Above
      Strategy
                                        Minimum       $5MM       $10MM       $25MM     $50MM      $100MM     $100MM
      Municipal Ultra Short               $1MM        20 bps     17 bps      14 bps     14 bps    12 bps     10 bps

      Municipal Ladders                   $250K       20 bps     17 bps      14 bps     14 bps     12 bps    10 bps

      Municipal Intermediate Value        $500K       35 bps     30 bps      25 bps     20 bps    17.5 bps   15 bps

      Municipal Extended Value            $500K       35 bps     30 bps      25 bps     20 bps    17.5 bps   15 bps

      Municipal Opportunistic Value       $2MM        50 bps     40 bps      30 bps     30 bps    27.5 bps   25 bps

      Municipal Defeasement               $1MM        12 bps     12 bps      12 bps     12 bps    12 bps     12 bps

      Municipal Tax Liability             $1MM        8 bps       8 bps       8 bps     8 bps      8 bps      8 bps

      Government Defeasement              $1MM        10 bps     10 bps      10 bps     10 bps    10 bps     10 bps

      Government Tax Liability            $1MM        6 bps       6 bps       6 bps     6 bps      6 bps      6 bps

Form ADV Part 2A Annual Amendment March 31, 2022

   Government Ladders                 $1MM        16 bps     14 bps       12 bps    12 bps     11 bps    9 bps

 Strategies with Blended Fee Schedule Aggregated by Client Family Group
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Types of Clients

Description
Gurtin’s clients consist of individuals, high net worth individuals, charitable organizations, investment
companies, pooled investment vehicles, pensions, retirement and profit-sharing plans (but not plan
participants), corporations and other businesses, and insurance companies.

Account Minimums for Individual Clients and for Clients of Intermediary Firms
See Fee Schedule under Fees and Compensation. Minimums may be lower than the above for customized
accounts. Gurtin may waive the account minimum or require a higher or lower minimum upon prior
written notice. These minimums may be waived or modified as Gurtin deems appropriate with respect to
each individual account and client.

Methods of Analysis, Investment Strategies and Risk of Loss

Methods of Analysis & Investment Philosophy
Gurtin is steadfast in the belief that fixed income should represent the low risk portion of a client's overall
investment portfolio, and therefore, we will not sacrifice credit quality to achieve higher returns. We
believe this is optimally achieved by building fixed income portfolios that are broadly diversified and by
minimizing credit risk exposure. In structuring our portfolios, we perform our own in-depth fundamental
analysis to identify what we believe are the most resilient sectors based upon ability to generate revenue,
financial flexibility, and downside risk. We then perform granular research on the obligors within sectors
to identify what we believe are the highest quality bonds, followed by ongoing surveillance on all bonds
in our portfolios. In our efforts to preserve principal, we ensure proper diversification by setting clearly
defined portfolio concentration limits on sector, state of issuance, and individual obligor. Gurtin is
generally not required to consider the tax status or tax needs of a client when managing investments,
although it may choose to do so.

Form ADV Part 2A Annual Amendment March 31, 2022

Portfolio Construction Process
Our portfolio construction process begins with the development of a dynamic top-down analysis of the
ever changing outlook for the economy, followed by a qualitative and quantitative bottom-up individual
security selection process that focuses on securities that we believe are sustainable, and exhibit the best
risk-adjusted after-tax yields. Our top-down research process involves a broad-based global analysis of
macroeconomic factors, industry trends, and investment themes, as well as a determination of which types
of security structures we believe will outperform given strategy objectives. Our economic outlook and
structural analyses are used as the basis for our bottom-up investment strategy, in which we incorporate
fundamental credit analysis to ensure high portfolio credit quality and attractive risk adjusted after-tax
returns.

Although portfolio management requires some degree of subjectivity, in that it involves a considerable
amount of expert judgment, we have worked to make our process as objective, consistent, and repeatable
as possible by relying heavily upon quantifiable factors (such as credit requirements, bond structure,
portfolio sector composition, etc.) for security selection.

Buy / Sell Discipline
Buying
We purchase, among other securities, high grade domestic Municipal, US Government, US Government
Agency securities, and short-term money market securities for our portfolios; we do not purchase
derivative instruments or commodity interests. We broadly diversify our portfolios, generally averaging
30-40 issues per portfolio, although this number may be lower or higher based on the size of the account
as we place priority on balancing diversification and liquidity.

Using our market knowledge, research capabilities, and quantitative analysis, we only buy bonds that we
believe are attractively priced relative to the fixed income market. We are patient in our approach to
investing in fixed income securities for our clients. We prefer to purchase bonds that offer strong liquidity
for our clients. We do not have a size requirement for our bond purchases. We can buy smaller blocks if
they are attractively priced as well as very large blocks (multiple millions) of bonds.

Our Social Advancement approach serves as a complimentary strategy overlay for clients interested in
municipal investments that seek to advance social or environmental objectives. Social Advancement
portfolios utilize our proprietary technology and credit research to enable discovery of high-quality
municipal bonds with which we identify as having a social advancement purpose while maximizing risk
adjusted, after tax yield. The Social Advancement strategy overlay generally avoids projects that primarily
benefit the private sector or have clear negative social or environmental consequences. Bonds purchased
for Social Advancement are still subject to our standard credit discipline. An individual security is eligible
for inclusion in the Social Advancement strategy overlay, and its sub-classifications, based on several
factors including, but not limited to, the security’s use of proceeds. Gurtin uses its best efforts to identify
securities, where, in our opinion, a substantial portion of the proceeds satisfy the goals of the Social
Advancement strategy overlay. The determination by us of a security meeting the internal requirements
for classifications as “Social Advancement”, or its sub-classifications, is solely based on information
provided by an issuer in official statements at the time of the initial security’s issuance (including any
refundings). No examination or audit is conducted on actual use of proceeds.

Selling
We sell any bonds that do not meet our credit quality threshold. In addition to selling securities due to
credit deterioration; we will also sell bonds opportunistically to enhance portfolio yields and when client

Form ADV Part 2A Annual Amendment March 31, 2022
...