Piton Investment Management LP

Item 5: Fees and Compensation

Investment Advisory Services

Piton offers fixed-income and customized investment advisory services for a fee. For
Discretionary Management Accounts and Sub-Advised Accounts, fees are stated as an annual
percentage of assets under management, generally range between 0% and 1.0%, and are
charged in arrears. Piton has full discretion to negotiate fees based on certain criteria, such
as, but not limited to, complexity of the management strategy, mandate size, related
accounts, preexisting relationships and account composition.

The amount of fees, periods over which fees are calculated, and method of payment of fees
will be documented in a written agreement prior to engagement. Such factors will vary based
on the requirements of individual Clients. Fees can be deducted from the account invoiced
to the Client, the Client’s financial consultants, or to the Client’s custodian as directed by
the Client.

SMArtX Advisory Solutions LLC (“SMArtX”) Platform
Piton has entered into an Investment Advisory Agreement with SMArtX Advisory Solutions
LLC (“SMArtX”). SMArtX is an investment adviser registered with the SEC and has
established and operates an advisory platform comprised of selected managers that provide
discretionary advisory services to certain their clients. SMArtX has retained Piton to
perform discretionary investment management services with respect to designated client
accounts on the SMArtX Advisory Platform. Piton will be paid an annualized investment
management fee based on the assets managed (including any accrued income) with respect
to each designated client account in accordance with the fee schedule assigned to the
applicable strategy through the SMArtX Advisory Platform.

Piton Investment Management, L.P.                                          Form ADV Part 2A

HIS Protective Investments TAMP Platform
Piton has entered into a sub-manager agreement with HIS to offer customized institutional
fixed income and structured notes on their Protective Investment TAMP. HIS has
established and operates an advisory TAMP platform comprised of selected managers (sub-
advisors) that provide customized investment strategies to clients of the HIS TAMP. Piton
will be paid an investment management fee based on the assets managed (including any
accrued income) for each client account in accordance with the fee schedule assigned to the
applicable investment strategy selected on HIS’s TAMP Platform.

Piton’s Clients will often also incur charges imposed by third parties, such as, but not limited
to, broker-dealers, custodians, trust companies, other investment advisors, banks and other
financial institutions. These charges could include securities brokerage commissions, ticket
charges, transaction fees, trade-away fees, custodial fees, borrowing expenses, charges
imposed directly by a mutual fund or ETF in a Client’s account (as disclosed in a fund’s
prospectus), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions.

Consulting Services

Piton performs consulting, advisory, sub-advisory and related services to and for Clients as
reasonably requested and agreed to by Piton from time to time, including, but not limited to,
(i) evaluating specific assets; (ii) providing market information; (iii) advising Clients on a
course of action; (iv) providing portfolio management advice; (v) processing and executing
trades and (vi) providing sub-advisory services.

Clients enter into a separate Services or Investment Advisory Agreement with Piton for
consulting services in either an ongoing manner or in a short-term manner. Management fees
generally range from 0 to 1%. For consulting services on an ongoing manner, the fee is
annual, paid monthly in arrears and negotiable. There are also flat fees for certain services
and these fees will depend on the nature of such services, as agreed to by both parties in the
Services Agreement. For consulting services in a short-term manner, fees are generally
calculated in arrears based on asset values and negotiated on an ad hoc basis depending on
the scope, complexity, length of the engagement and services to be provided, as agreed to
by both parties in the Services Agreement. Fees are deducted from the account, invoiced to
the Client, the Client’s financial consultants, or to the Client’s custodian as directed by the
Client.

Piton’s Clients will often also incur charges imposed by third parties, such as, but not limited
to, broker-dealers, custodians, trust companies, other investment advisors, banks and other
financial institutions. These charges could include securities brokerage commissions, ticket
charges, transaction fees, trade-away fees, custodial fees, borrowing expenses, charges
imposed directly by a mutual fund or ETF in a Client’s account (as disclosed in a fund’s
prospectus), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions.

Sub-Advisory Services

PIFI Exchange Traded Fund (“ETF”)
Piton serves as the portfolio manager to the Piton Intermediate Fixed Income ETF (NYSE:
PIFI). Piton acts in the capacity as sub-advisor to ClearShares LLC, the advisor to PIFI.
Within PIFI, Piton seeks to provide a diversified portfolio of high-grade fixed income

Piton Investment Management, L.P.                                           Form ADV Part 2A

securities with an average life and interest rate risk profile that is lower than many “core”
intermediate fixed income ETFs. Generally, the PIFI portfolio will contain a mix of US
treasury securities, US government agency bonds, corporate debt, and other high-grade
securities in accordance with our macro-economic outlook.

PIFI’s Annual Fund Operating Expenses (expenses that you pay each year as a percentage of
...

Item 7: Types of Clients

Piton offers its services to institutional, individual, and high net worth individual Clients.
Clients include individuals, other investment advisors, family offices, banking or thrift
institutions, insurance companies, trusts, estates, broker-dealers, charitable institutions,
foundations, endowments, sovereign and domestic government entities, corporations and/or
other business entities and other institutional investors, collectively “Clients”.

Account minimums are subject to negotiation. Generally, Piton requires a minimum account
size of $250,000. The Firm, in its sole discretion, accepts Clients with smaller portfolios
based upon certain criteria, such as anticipated future earning capacity, anticipated future
additional assets, dollar amount of assets to be managed, related accounts, account
composition, pre-existing client relationships, account retention, and pro bono activities.
Piton only accepts Clients with less than the minimum portfolio size if, in the sole opinion of
the Firm, the smaller portfolio size will not result in a substantial increase of investment risk
beyond the Client’s identified risk tolerance. Piton, in its sole discretion, also aggregates the
portfolios of family members or related accounts to meet the minimum portfolio size.

Piton Investment Management, L.P.                                           Form ADV Part 2A