PGIM Custom Harvest LLC

ITEM 5. FEES AND COMPENSATION
How PGIM Custom Harvest is compensated for its services depends on whether PGIM Custom Harvest provides services
under an advisory agreement directly with the client (commonly referred to as “Dual Contract Arrangements”) or provides
services pursuant to an agreement with a managed account program sponsor, including a Wrap Fee Program sponsor (commonly
referred to as “Single Contract Arrangements”).

PGIM Custom Harvest has adopted policies, including valuation and fee billing policies, that govern the pricing of assets in
client accounts, including ETF holdings, and the calculation of advisory fees. The policies are supported by procedures intended
to promote accurate pricing and fee calculations. PGIM Custom Harvest believes that these policies address the conflicts of
interest associated with calculating client advisory fees.

Dual Contract Arrangements:

Under Dual Contract Arrangements, PGIM Custom Harvest calculates investment advisory fees based upon a percentage of the
value of client accounts. The specific manner in which fees are charged by PGIM Custom Harvest is established in a client’s
written agreement (i.e., a Client Service Agreement) with PGIM Custom Harvest. PGIM Custom Harvest’s current standard
form of Client Service Agreement provides that PGIM Custom Harvest’s investment advisory fees are charged quarterly in
advance upon inception of management. Previously, PGIM Custom Harvest has entered into agreements with clients under
Dual Contract Arrangements that provide for investment advisory fees to be charged in arrears. If an account commences
management during a quarter, the investment advisory fee for that quarter is prorated. PGIM Custom Harvest has adopted
policies that provide for a pro rata refund of any prepaid advisory fees upon account termination.

PGIM Custom Harvest has adopted policies, including valuation and fee billing policies, designed to ensure that assets in client
accounts, including ETF holdings, are priced accurately for fee billing purposes and that advisory fees are calculated and debited
correctly. PGIM Custom Harvest believes that such policies address any conflict of interest faced by PGIM Custom Harvest in
calculating client advisory fees. Under certain Dual Contract Arrangements, the program sponsor may calculate PGIM Custom
Harvest’s fees based on the fee rate agreed to by the client and PGIM Custom Harvest and the value of client account assets, as
determined by the program sponsor.

PGIM Custom Harvest advisory fees are charged to clients. For client accounts from which fees are withdrawn by the custodian
and paid over to PGIM Custom Harvest:

    1.   Clients must provide written authorization (which is typically provided in the investment management agreement or
         Client Service Agreement) permitting fees to be withdrawn from the client’s account and paid over to PGIM Custom
         Harvest upon the direction of PGIM Custom Harvest.

    2.   Pursuant to the written authorization provided by the client, PGIM Custom Harvest will bill the custodian the amount
         of the fee, as calculated based on each client’s agreement with PGIM Custom Harvest, or request that the program
         sponsor calculate the amount of the fee owed to PGIM Custom Harvest and pay such fee over to PGIM Custom
         Harvest.

    3.   The custodian will send to the client, at least quarterly, a statement that details the amounts disbursed from the account,
         including any advisory fees paid by the custodian directly to PGIM Custom Harvest. Clients who have authorized PGIM
         Custom Harvest to instruct the custodian to deduct its advisory fee from their account should review the statements
         they receive from their custodian. PGIM Custom Harvest’s ability to instruct the custodian to pay its fees from a client’s
         account will result in PGIM Custom Harvest being deemed to have custody (see Item 15) of the assets in such client
         account.

A client may terminate the client’s Client Service Agreement or other investment advisory agreement with PGIM Custom
Harvest by providing notice to PGIM Custom Harvest in accordance with the provisions of the agreement. Investment advisory

7 PGIM Custom Harvest (FORM ADV PART 2A)

FORM ADV—PART 2A
FORM ADV—PART 2A

fees typically will accrue through the date of termination.

Fees for all services for clients are generally negotiable depending on the selected investment strategy, the size of the client’s
investment or the size of the overall relationship with the client’s financial adviser, the scope and complexity of the services and
other factors. Because fees are negotiable, the actual fees paid by any client or group of clients might differ from the fees
discussed below (i.e., may be a flat fee, may include fee breakpoints, or be higher in certain cases). Sponsors may also require
that the fee be calculated and billed in accordance with their procedures and methodologies that differ from the those described
above.

Standard Fee Schedule for Dual Contract Arrangements:

The table below reflects our standard fee schedule by type of strategy. PGIM Custom Harvest may offer fee breakpoints based
upon the account’s asset size. Fees are typically charged quarterly in advance.

             Account Value                    Equity             Hedged and Long/Short              Fixed Income
         (Minimum Account Size
               and above)

         $100,000 and above          32 basis points (0.32%)                                 25 basis points (0.25%)

         $500,000 and above                                     50 basis points (0.50%)

Single Contract Arrangements:

Under Single Contract Arrangements, the program client compensates the sponsor for its investment advisory and other services,
and the program sponsor, in turn, compensates PGIM Custom Harvest for its investment advisory services. Under Single
...

ITEM 7. TYPES OF CLIENTS
PGIM Custom Harvest provides TLH investment advisory services to various types of clients, including high net worth and
other individuals, trusts, corporations/other businesses, registered investment advisers and other financial intermediaries. Given
the tax-oriented nature of its investment strategies, PGIM Custom Harvest’s clients are predominantly U.S.-based. However,
PGIM Custom Harvest may accept a non-U.S. based client in its discretion. In addition, PGIM Custom Harvest’s strategies are
not designed for tax-exempt investors as such clients will not generally benefit from the TLH component of the strategies.
PGIM Custom Harvest’s minimum account size for strategies (other than its hedged and long/short strategies) is generally
$100,000. PGIM Custom Harvest’s minimum account size for its hedged and long/short strategies is $500,000. PGIM Custom
Harvest’s minimum account size for a custom strategy is $1,000,000. PGIM Custom Harvest’s minimum account size for clients
seeking to provide customized transition instructions in connection with PGIM Custom Harvest’s provision of transition
services is $500,000. PGIM Custom Harvest may waive the applicable minimum for any one or more client accounts. In addition,
PGIM Custom Harvest and a program sponsor may establish investment minimums for accounts under a particular sponsor
program that are higher or lower than those indicated above.

11 PGIM Custom Harvest (FORM ADV PART 2A)

FORM ADV—PART 2A
FORM ADV—PART 2A