Provenio Capital Management LLC

ITEM 5 – FEES AND COMPENSATION

FEE SCHEDULE
Investment Advisory Services
Provenio Capital's advisory fees for investment advisory services generally range from 0.25% to 1.00% annually,
calculated as a percentage of assets under advisement (AUA). The specific fee charged to a client within this range is
determined based on factors including, but not limited to, asset class, account size, portfolio complexity, and scope of
services provided, and is set forth in each client's investment advisory agreement.

Our standard fee schedule is negotiable based on several factors, which include but are not limited to "grandfathered"
accounts, related accounts, and other structures that we consider in special situations. Provenio Capital manages
some accounts without charge at their discretion.

Insurance Dedicated Fund
An Insurance Dedicated Fund (“IDF”) is a fund managed by an investment manager, typically designed for segregated
asset accounts (separate accounts) of insurance companies that issue Private Placement Life Insurance (PPLI) and
Private Placement Variable Annuities (PPVA). The insurance companies issue policies to policyowners who invest in
the IDF.

As the manager and sub-adviser of the IDF, Provenio Capital receives a percentage-based fee on the assets invested
in the fund. IDF fees are set forth in the applicable IDF's offering documents and are determined independently of, and
may differ from, the fee range described above under Investment Advisory Services. Asset valuations occur monthly,
though some funds may be valued quarterly. Provenio Capital receives fee payments on a quarterly basis in arrears,
calculated based on the aggregate assets under management (AUM) within the IDF.

Separately Managed Accounts
The policyholder may allocate cash value to an investment managed by an independent investment manager, such as
Provenio Capital. This account is permitted to invest in a broader range of investments, not limited to IDFs. The
independent investment manager may operate under an investment policy statement and, similar to an IDF, manages
the account on a discretionary basis. A separately managed account (“SMA”) is typically established for a single
individual or family, whereas an IDF may include multiple insured parties. In both cases, the investor control doctrine
and diversification rules apply.

Fees charged to SMA clients are separately negotiated between Provenio Capital and the applicable insurance carrier
and are set forth in the agreement between Provenio Capital and the insurance carrier. These fees are determined
independently of, and may differ from, the fee range described above under Investment Advisory Services. The invested
assets are valued as per the SMA governing documents provided by the insurance carrier. Provenio Capital receives fee
payments on a quarterly basis in arrears based on the aggregate AUM invested in the SMA. The administrator and/or
the insurance carrier calculates and facilitates all fee payments to Provenio Capital.

Co-Investments
Fees assessed for each co-investment will be based on performance rather than assets under management. Please
refer to the governing documents, subscription agreements and any investment management agreement between
Provenio Capital and each co-investment for the specific fee and compensation arrangement.

All organizational and operating expenses of the co-investment will be paid by the co-investment, excluding any
regulatory expenses, or other costs incurred by the general partner in connection with its daily operations, including
but not limited to salary and other payments to employees or officers of the general partner.

In addition, each co-investment will pay, or reimburse the general partner or its affiliates for, or will be responsible for
operating costs and expenses incurred by it or on its behalf, including (i) out-of-pocket expenses that are associated
with disposing portfolio company securities, including transactions not completed; (ii) extraordinary expenses, if any
PROVENIO CAPITAL MANAGEMENT LLC
Form ADV Part 2A Brochure | July 21, 2026                                                                     Page 7 of 21

(such as certain valuation expenses, litigation and indemnification payments); (iii) interest on borrowed money,
investment banking, financing and brokerage fees and expenses, if any; (iv) expenses associated with the co-
investment’s tax returns and Schedules K-1, custodial, legal and insurance expense, any taxes, fees or other
governmental charges levied against the co-investment; (v) attorneys’ and accountants’ fees and disbursements on
behalf of the co-investment; (vi) insurance, regulatory or litigation expenses (and damages); (vii) expenses incurred in
connection with the winding up or liquidation of the co-investment (other than liquidation expenses permissible under
the governing documents); (viii) expenses incurred in connection with the winding up or liquidation of the co-investment
(other than liquidation expenses permissible in the governing documents); (ix) expenses incurred in connection with
any amendments to the constituent documents of the co-investment and related entities, including the general partner;
and (x) expenses incurred in connection with the distributions to the investors in the co-investment and in connection
with any meetings called by the general partner.

Other Planning Services
Provenio Capital offers other planning services for a mutually agreed upon flat fee. Fees may range between $5,000
and $50,000 depending on the scope of services performed.

BILLING METHOD
Investment Advisory Services
Provenio Capital’s advisory fees are payable quarterly in arrears. Provenio Capital excludes cash positions from the
billable value of the account. Billable values are based on the average daily market value of the account during the
quarter, where available. If daily pricing is not available, billable values will be based on the most frequently available
...

ITEM 7 – TYPES OF CLIENTS

Provenio Capital provides advisory services to individuals, high net worth individuals, trusts and estates, foundations,
individual participants of retirement plans, pension and profit-sharing plans, businesses, insurance companies and the
co-investments.