New Capital Management LP

5. Fees and Compensation

New Capital Management is only compensated by fees paid directly by its clients. NCM does not
receive commissions, does not receive payments from third parties, and has no financial interest
in any services or investment products employed for its clients. Accordingly, NCM has no
fee-related conflicts of interest and therefore no incentive to recommend investment products
based on the compensation received, rather than on a client’s needs. When NCM recommends
mutual funds for clients, they are no-load funds (i.e., they have no sales charges).

NCM assesses its fee based on the following standard fee schedule:

                                     Breakpoint                   Fee basis
                                     $1 million and less          0.75%
                                     $1 million - $3 million      0.70%
                                     $3 million - $5 million      0.60%
                                     $5 million - $8 million      0.50%
                                     $8 million - $20 million     0.40%
                                     $20 million - $100 million   0.30%
                                     $100 million +               0.20%

NCM’s fees are not generally negotiable. New Capital regularly participates in and analyzes
surveys of advisors that offer services and investments similar to our own, and we establish our
fee schedules with reference to the results of these surveys. We believe our fees are generally in
line or below industry medians. In rare circumstances NCM may negotiate to charge a greater or

New Capital Management – Form ADV II ​ ​    ​      ​       ​       ​      ​         ​   March 31, 2026

lesser fee based upon certain criteria, including but not limited to asset class, services rendered,
anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to
be managed, related accounts, account composition, pre-existing client relationship, account
retention, pro bono activities, client referrals, client tenure, or financial hardship.

Fees are deducted quarterly in advance directly from pre-determined discretionary client
accounts (clients may select how to apportion fees among their accounts). NCM delivers a fee
billing statement along with its quarterly reports to clients. Additionally, fees are reflected as
“Advisor Fee” on the client’s broker custodian statement. NCM also sends an end of year report
to clients showing all fees billed for the year by account. A $2,500 minimum annual fee applies
to all households, and this minimum means that any household with under $333,000 in assets
under management would incur a rate higher than NCM’s maximum rate of 0.75%.

Clients incur additional management fees from any mutual or other funds used for portfolios.

Clients also incur brokerage transaction fees from NCM’s main custodian, Fidelity Investments,
for trading securities, as follows:
                                                       Household< $1M         Household> $1M
             Equities and ETF’s                        $4.95                  $0
             No transaction fee mutual funds           $0                     $0
             Transaction fee mutual funds              $15                    $15

Clients are assessed a pass-through technology fee by Orion Advisor Technology, LLC for
account reporting and management services, as follows:

                                                                         Flat Fee
                           NCM Account Fee
                                                                       (quarterly)
                           Custodial (Fidelity, Interactive Brokers,
                                                                              $11
                           Brighter Futures 529 Plan, etc.)
                           ByAllAccounts (Service Program C)                  $20
                           Reporting Only                                     $5

As clients pay NCM’s quarterly retainer fee in advance, any terminating client may obtain a
refund of this pre-paid fee if the advisory contract is terminated before the end of the billing
period. The refund is made pro rata on the days remaining in the quarter.

NCM currently uses Fidelity Investments as its primary broker. While NCM could elect to use
another primary broker(s), NCM gains efficiency advantages from its use of a sole broker and
believes those efficiencies allow it to maintain a relatively lower fee structure than industry
average. Additionally, NCM does not believe that other brokers are able to render services at
meaningfully lower rates than those negotiated by NCM with Fidelity. However, Fidelity’s
surcharge on Dimensional and Vanguard funds causes NCM to carefully evaluate the benefits of
any particular trading initiatives in client accounts.

New Capital Management – Form ADV II ​ ​   ​   ​       ​     ​      ​       ​      March 31, 2026

7. Types of Clients

NCM provides investment advice mostly to families and individuals (including high net worth
individuals), but also to related trusts, businesses, charitable foundations, and pension funds.
While NCM does not have any stated requirements for opening or maintaining an account, such
as a minimum account size, the majority of NCM’s clients have at least $1,000,000, and
frequently more, in net household investable assets. The average household account size is
approximately $4.1 million. A majority of clients are in Houston, but there are also clients in
other parts of Texas, in other U.S. states, and in other countries.