Penn Capital Management Company LLC

Item 5 - Fees and Compensation

Penn Capital investment advisory and sub-advisory clients pay fees that typically vary from client to client
depending on the type, size, complexity of the client account, or the vehicle in which a client invests (e.g.,
mutual funds, private investment funds, SMAs, wrap fee programs, Model Accounts). Fees for products

Penn Capital Management Company, LLC
Form ADV Part 2A

other than registered mutual funds typically are individually negotiated and generally reflect, among other
considerations: specific investment mandate(s), service needs, history with Penn Capital, account size,
including related accounts under management, and reporting requirements. From time to time Penn
Capital will give certain investors in SMAs more favorable economic terms than other investors in the
same investment vehicle or within the same or similar investment strategy, including with respect to both
management and performance-based fees, which terms generally take into account certain factors,
including but not limited to the timing and aggregate size of investments with Penn Capital of such client.
Penn Capital does not require the prepayment of fees.

Registered Mutual Funds:
The fees payable on assets, including SMA assets, invested in the registered mutual funds of the RBB Funds
Trust (“Trust”) are paid by the investor in accordance with the fees and expenses identified in each
registered mutual fund’s prospectus. Shares of the affiliated mutual funds in the Trust can be purchased
through various distribution channels (i.e., mutual fund supermarket platforms, and other investment
advisers’ separate account models) that are not affiliated with Penn Capital.

Investment advisory fees payable to Penn Capital by each registered mutual fund in the Trust are stated
in such fund’s Prospectus.

SMAs:
Generally, SMA fees are calculated and paid quarterly in arrears and are prorated, if necessary, based on
the period the assets were under management, including adjustments for significant additions or partial
withdraws. Penn Capital typically invoices clients on a quarterly basis, unless otherwise negotiated by a
client.

Penn Capital’s standard investment advisory fees generally range from 0.30% to 1.25% depending upon
the specific investment strategy. Fee breakpoints are also available depending upon total assets invested
with Penn Capital. Generally, fees are based upon the market value of the account at the end of each
calendar quarter, although clients are permitted to request other arrangements. If the account uses
margin (borrowed assets), the fee is charged on the total assets.

Wrap Fee Accounts, Model Accounts and Unaffiliated Registered Mutual Funds:
Penn Capital does not determine the fee that investors pay to: unaffiliated registered mutual funds for
which Penn Capital acts as sub-adviser, Model Accounts, or Wrap Fee Accounts. Penn Capital separately
negotiates its advisory fees for its sub-advisory services provided to these products. Typically, the mutual
fund investment adviser, Model Account sponsor, or wrap fee program sponsor pays Penn Capital from
the unaffiliated mutual fund adviser’s or wrap fee program sponsor’s own management fees. Where Penn
Capital does not exercise investment discretion, (e.g., Model Accounts), the negotiated fee could be lower
than those negotiated for discretionary investment advisory services, depending upon the circumstances.
Underlying clients of Model Accounts or Wrap Fee Accounts should contact the sponsors of such programs
directly for information about the investor’s total costs to participate in such programs.

Other Costs and Expenses:
In addition to the investment advisory fees described above, clients typically bear other costs associated
with investments or accounts including but not limited to, and only as applicable for the client’s specific
situation: (i) custodial charges, brokerage fees, exchange fees, mutual market access fees, commissions
and related costs (see Item 12 – Brokerage Practices for more information); (ii) interest expenses; (iii)

Penn Capital Management Company, LLC
Form ADV Part 2A

taxes, duties and other governmental charges; (iv) transfer and registration fees or other similar expenses;
and (v) costs associated with foreign exchange transactions. With respect to such services (which typically
include, but are not limited to, custodial, securities lending, brokerage, banking, consulting or third-party
advisory services) SMA clients are required to establish business relationships with relevant service
providers or other counterparties.

Clients also incur trading costs such as brokerage or transaction fees for services provided by entities other
than Penn Capital, and which are not reflected in Penn Capital’s advisory fee. For more information
regarding brokerage practices and related costs, please refer to Item 12-Brokerage Practices below. On a
limited basis, Penn Capital has the ability to invest in other non-affiliated pooled investment vehicles (e.g.,
exchange-traded funds or closed-end investment companies). Penn Capital’s advisory fee is in addition
to, and does not include the internal management, operating, or distribution fees or other expenses
incurred by these other products.

Item 6 - Performance Fees & Side-by-Side Management

Penn Capital has entered into performance fee arrangements with certain qualified clients, as defined by
Rule 205-3 of the Investment Advisers Act of 1940, as amended (“Advisers Act”). Performance fees are
subject to individualized negotiations. Penn Capital will structure a performance or incentive fee
arrangement in accordance with applicable laws and related exemptions. The base fee is calculated based
upon the market value of the account, while the incentive fees generally are paid annually, or upon
liquidation of a client’s account.

Performance based fee arrangements have the potential to create an incentive to recommend
...

Item 7 - Types of Clients

Penn Capital offers investment advisory services to: corporate retirement, pension, and profit-sharing
plans; Taft-Hartley plans; registered mutual funds; US and international pooled investment vehicles and
sub-advised arrangements; insurance companies; charitable institutions; foundations; endowments;
municipalities; banking or thrift institutions; corporations; non-US funds; and other institutions,
investment advisers, individuals, and high net worth individuals.