Nottinghill Investment Advisers Ltd

Fees and Compensation

       The annual fee schedules associated with the fully discretionary investment strategies of
       Nottinghill Investment Advisers, Ltd., are the following:

       Yield Plus Equity Strategy
          1.0% of the first $1 million
          0.75% of the next $4 million
          0.50% of remaining assets

       Yield Pure Equity Strategy
          1.0% of the first $1 million
          0.75% of the next $4 million
          0.50% of remaining assets

       Total Portfolio Management
          Equity and Alternative Components
          Same as Yield Plus and Yield Pure

          Fixed Income Component
          0.25% of total assets

       Indexed Total Portfolio Management
          0.60% of the first $250,000
          0.50% of the next $750,000
          0.40% of remaining assets

       Nottinghill employs two methods for charging investment management fees.

       Regarding the Nottinghill accounts of March 31, 2026, and all Nottinghill accounts to come
       and not described below, all investment management fees are based upon total portfolio
       market value at the beginning of the calendar quarter, and are billed either to the client or

the custodian of the client’s assets quarterly in advance, at one-fourth of the above rates.
(If the custodian is billed directly, the client receives a copy of the invoice in all cases.) If
supervision of a client portfolio begins intra-quarter, the portfolio is valued, and the fee is
pro-rated over the period until quarter-end. Alternatively, if portfolio management services
are terminated intra-quarter, the fee for that quarter is pro-rated over the period in which
assets were under supervision. In other words, if an entire quarter’s fee has been paid in
advance, a portion of that fee will be refunded.

Beginning April 1, 2023, the accounts of a second investment adviser were managed by
Nottinghill. In these cases and only in these cases, all investment management fees will be
based upon total portfolio market value at the end of the calendar quarter, and will be billed
either to the client or the custodian of the client’s assets quarterly in arrears at one-fourth
of the applicable rates. (As before, if the custodian is billed directly, the client receives a
copy of the invoice in all cases.) If, in this subset of client accounts, portfolio management
services begin on a day other than the last day of the quarter, the portfolio is valued, and
that quarter’s fee is based on that valuation and prorated over the period from that date until
quarter-end. If, in this subset of client accounts, portfolio management services are
terminated intra-quarter, the portfolio will be valued on the termination date, and the fee
for the quarter will be prorated over the period in which the assets were under supervision.
Again, the practice of billing in arrears, as well as the related decision to continue billing
in accordance with each client’s March 31, 2023, fee schedule, are special arrangements
applicable only to this particular subset of accounts. The decision to maintain the original
fee schedules associated with the second investment adviser may result in higher or lower
investment management fees than those associated with other Nottinghill clients for similar
services.

The above standard fee schedules are negotiable. The factors involved are many and
varied; however, portfolio size and the competitive environment frequently are important.

The fees payable under the above standard fee schedules are for investment management
services only. These fees do not include any bank or brokerage charges for security
transactions, the custody of assets, or any other related services.

The minimum fee for investment management services under all standard schedules is
$250 per quarter. This minimum fee can be waived at the discretion of a Managing
Director.

Nottinghill also provides subscription/research services to a second investment adviser
who utilizes these services in the management of that adviser’s client assets. The fee for
these services is based upon several factors, including the aggregate total of the assets
involved and the size of the individual accounts involved.

Nottinghill also provides a standalone investment planning process/tool to both Nottinghill
clients and non-clients. In both cases, fees are negotiable.

Form ADV Part 2A
Nottinghill Investment Advisers, Ltd.
March 31, 2026

Types of Clients

       Nottinghill Investment Advisers, Ltd., serves a variety of both taxable and tax-exempt
       clients on a fully discretionary basis. On December 31, 2025, the former accounted for
       70% of total assets under management, while the latter accounted for the remaining 30%.
       Individuals & Trusts portfolios accounted for all of the taxable assets; the largest tax-
       exempt client group, on the other hand, was the IRA group whose retirement assets
       accounted for 23% of total Firm assets. Of the 75 portfolios managed (all client types),
       eight of these were equity portfolios, and the remaining 67 were balanced portfolios
       containing both equities and fixed income securities.

       Regardless of client type or the investment strategy employed, investment accounts may
       be opened with $250,000 or more. Nottinghill may elect to waive this minimum under
       special circumstances; there is no minimum associated with maintaining an account.

       On February 1, 2017, Nottinghill also began providing subscription/research services to
       another investment adviser. That adviser utilizes these services in the management of
       client assets.

       On January 1, 2025, Nottinghill also began providing the Path Ahead analysis, an
       investment planning process/tool, on a standalone basis.

Form ADV Part 2A
Nottinghill Investment Advisers, Ltd.
March 31, 2026

                       Methods of Analysis, Investment Strategies,
                                     Risk of Loss

       Nottinghill Investment Advisers, Ltd., is a rules-based manager of equity and balanced
       portfolios. In fact, approximately 95% of the Firm’s decision-making processes in the
       aggregate is based upon the discipline of numbers. The remaining 5% is a review, based
       upon fundamental factors, of the indicated buy/sell decisions. Four specific investment
       strategies are provided to a substantial majority of Nottinghill clients, and are marketed
       actively. In addition to being quantitative and highly disciplined, these Nottinghill
       strategies emphasize large capitalization, primarily value-oriented equities, typically
       involve multiple independent sets of buy/sell disciplines in the portfolios’ actively
       managed components, and do not depend upon high levels of asset turnover for their
       success. Unfortunately – and this is the case with most if not all equity and balanced
       investment strategies – the possibility of capital loss does exist.

       Nottinghill’s flagship equity strategy is Yield Plus. Portfolios typically contain 10-15
       individual stock holdings and shares in certain Exchange-Traded Funds. Two groups of
       independently managed securities are involved. One group is managed in accordance with
       certain value-oriented disciplines, and the second in accordance with more growth-oriented
       criteria. The principal risk in both cases is equity market risk, i.e., the risk associated with
       a decline in the overall equity market. A secondary risk associated with value-oriented
       criteria is that the indicated security in fact declines further for unforeseen fundamental
       reasons. A secondary risk associated with the growth-oriented criteria is that the
       underlying earnings per share growth diminishes, and the security, therefore, loses this
       valuable support.

       The second actively marketed Nottinghill strategy is Yield Pure. In this case, the first set
       of value-oriented buy/sell criteria mentioned above is employed in the management of the
       entire portfolio. Again, the principal risk is equity market risk, i.e., the risk associated with
       a decline in the overall equity market, and a secondary risk is that the indicated security in
       fact declines further for unforeseen fundamental reasons.

The third actively marketed Nottinghill strategy is Total Portfolio Management, or TPM,
a balanced strategy. At the portfolio’s center is Yield Plus governing large capitalization,
primarily Value equities. Three low-cost index funds or Exchange-Traded Fund shares
replicating those funds then give the TPM investor exposure to U.S. mid-capitalization,
U.S. small capitalization, and emerging markets (international) equities. Positions in
certain alternative asset classes, i.e., emerging markets government bonds, gold, and
REITs, add yet another layer of diversification, and finally, fixed income securities further
stabilize the pattern of investment returns. Regarding risk, again, equity market risk is the
principal one in the equity sector, with the above selection criteria risks also being factors.
In the fixed income sector, security prices generally will decline if interest rates rise. Rising
interest rates also are the principal risk associated with emerging markets government
bonds, while unfavorable supply/demand conditions are the principal risk associated with
commodities such as gold and the real estate constituting REITs.

The fourth actively marketed Nottinghill strategy is Indexed Total Portfolio Management,
or ITPM. Portfolio structure is comparable to that of a TPM portfolio, however, all
components in this case consist of low-cost index funds or Exchange-Traded Fund shares
replicating those funds. The principal risk within the portfolio’s equity sector, therefore,
is market risk, as opposed to any risk associated with individual security selection criteria.
Other portfolio risk factors, as described above, are those associated with rising interest
rates and the unfavorable supply/demand conditions that impact the commodity and real
estate markets.

Yield Plus, Yield Pure, Total Portfolio Management, and Indexed Total Portfolio
Management constitute Nottinghill’s Yield Plus Approach to Investing.

Form ADV Part 2A
Nottinghill Investment Advisers, Ltd.
March 31, 2026