Punch & Associates Investment Management Inc

Item 5        Fees and Compensation

GENERAL FEE INFORMATION

In cases where we are responsible for billing the client, individual client accounts are billed
quarterly in advance. Except in extraordinary circumstances, we do not adjust the billed
quarterly fee based on subsequent client contributions or withdrawals. Institutional client
accounts are also billed quarterly in advance, unless otherwise directed by the client. Clients
terminating their agreement before the end of the quarter will receive a pro-rated refund of the
fees paid in advance.

We deduct fees directly from the client’s custodial account, unless otherwise mutually agreed
upon.

                                                                            Dated March 31, 2026 | Page 5

                                                    PUNCH & ASSOCIATES | FORM ADV PART 2A

Clients will incur separate custodian, brokerage and transaction costs. Custodian fees are
negotiated by the clients and their selected custodian(s). In addition, we at times invest a
client’s account in registered investment companies or exchange-traded funds (“ETFs”) not
affiliated with us. In addition to our fees, clients are responsible for shareholder fees embedded
within the share price of these securities. Please see Item 12 for a discussion of our brokerage
practices.

FEE SCHEDULE

Private Client Fee Schedule

Our standard investment management fee for private client accounts is 1.00% of gross assets
under management.

Effective January 1, 2025, we offer to oversee accounts under a “supervised” structure which
allows us to apply our advisory services to accounts not invested in the Punch strategies,
review and comment on investment holdings, and report on account performance. Our
standard fee for “supervised accounts” is 0.50% of gross assets under supervision. We also
offer to maintain accounts not invested in the Punch strategies under our advisory platform
which allows us to view balances and assist with administrative matters, such as deposits,
wires, withdrawals, and allocation to cash alternatives, such as treasury bills and money market
options (“unmanaged accounts”). Our standard fee for “unmanaged accounts” is 0.10% of
gross assets under advisement. Collectively supervised accounts, unmanaged accounts and
Model Delivery assets (referenced below) are deemed “assets under advisement”.

Institutional Fee Schedule

Our standard investment management fee for institutional clients is tiered as follows:

               ASSETS UNDER MANAGEMENT                          FEE
                       Up to $10 Million                       0.85%
                Above $10 Million to $50 Million               0.80%
                Above $50 Million to $100 Million              0.75%
                      Above $100 Million                       0.72%

Model Delivery Fees

We receive between 0.30% - 0.40% from the Manager for the assets under management
which the Manager allocates to the Model Portfolio we provide.

Additional Notes

While we generally do not negotiate fees, we reserve the right to do so in certain circumstances
based on various factors, including account size and the size of future potential assets under
our management. For negotiated fee arrangements, we generally have applied either a fixed

                                                                            Dated March 31, 2026 | Page 6

                                                     PUNCH & ASSOCIATES | FORM ADV PART 2A

percentage or another tiered fee schedule to the client’s and, in select cases, to the related
family’s consolidated assets as agreed upon between the client and us.

We do not charge fees to employees and their family members (defined as spouses,
descendants, and descendants’ spouses). We also do not charge fees for management of
certain donor advised funds through which the firm and employees make charitable
contributions. While we do not currently charge performance-based fees on separately
managed accounts, we would consider entering into such an arrangement with select clients
eligible to pay performance-based fees in the future.

Wealth Advisory

We offer inclusive Wealth Advisory services for individual clients. We generally do not charge
an additional fee for Wealth Advisory services, but we reserve the right to negotiate fees
depending upon the complexity and circumstances of the client’s needs.

Private Fund

We collect asset-based and performance-based fees as adviser to each Private Fund, as fully
described in the Private Fund’s Confidential Private Placement Memorandum. Investors in
each Private Fund are encouraged to consult the Confidential Private Placement Memorandum
as the authoritative source for disclosure regarding fees paid to each Private Fund, as the
Private Fund’s standard fee schedules as outlined within the offering documents are generally
higher than the standard fee schedules described herein. The Private Funds’ administrator,
ALPS Alternative Investment Services, LLC (“ALPS”) calculates both the asset-based and
performance-based fees using the market value determined by an independent pricing service
as of the last day of the previous month-end. In addition, each Private Fund pays our firm a
monthly management fee calculated by ALPS for our role as the Managing Member.

While we are authorized to negotiate fees paid by investors in the Private Funds based upon
factors determined by us to be material, we have not and do not intend to negotiate such fees.
However, our employees and their family members invested in the Private Funds pay neither
investment management nor performance-based fees. See Item 6 for more information on

Item 7        Types of Clients

We manage assets for foundations, pension and profit-sharing plans, government entities,
corporations, high net worth individuals, families, trusts, private funds and donor advised funds.

                                                                            Dated March 31, 2026 | Page 8

                                                    PUNCH & ASSOCIATES | FORM ADV PART 2A

We also serve as a non-discretionary sub-adviser of an open-end, management investment
company registered under the Investment Company Act of 1940, as amended. At times, we
may group individual clients into applicable families for purposes of internal and external
reporting matters, including use in marketing materials.

We manage our firm’s profit-sharing plan as well as individual retirement accounts for
employees, and we direct accounts for our employees’ immediate family members. Please see
Items 11 and 12 for a discussion of our personal trading and firm trading practices.

Some of our clients may be executives or insiders of public companies. As these clients could
at any time be in receipt of material, non-public information about their affiliated company, we
maintain policies designed to ensure our investment management team does not inadvertently
gain access to such material, non-public information. In addition, employees are prohibited
from trading in securities of companies for which a client serves as an executive or an insider.

Our minimum account size for institutional clients is $10,000,000. We reserve the right to
increase or decrease this minimum account size or otherwise place limitations and covenants
on accounts. Our minimum Private Fund investor account size is addressed within the
Confidential Private Placement Memorandum. Our minimum account size for private client
accounts is $5,000,000. We have no specific minimum account size for Wealth Advisory clients.
At our discretion, we may waive our account minimums. Reasons we waive such minimums
include: the client is a family member or friend of firm management; we have a long-standing
relationship with the client; or we have an expectation to manage additional client assets in the
future. At our discretion, we will at times consider the size of underlying separately managed
portfolios of a client’s family members in determining the minimum account size.

We maintain separate relationships with certain individuals, for example:
• Select clients, vendors or other service providers used by firm clients (including broker-
  dealers) may be family members or friends of firm personnel, including firm owners. At
  times, firm personnel will engage in personal business dealings with these individuals as a
  natural extension of their outside personal relationships.
• Some clients are affiliated with entities which have a business relationship with the firm
  (such as firm vendors or other service providers used by firm clients), and certain of these
  entities have engaged us to manage their investment portfolios.

Given the inherently close working relationship we have with our clients, we expect
relationships with clients to continue to evolve over time. These expanded relationships present
an inherent incentive to provide preferential treatment to certain clients. We believe our firm’s
steadfast dedication to fairness and integrity, along with our policies and procedures designed
to ensure all clients are treated fairly as summarized within this disclosure brochure, help to
mitigate this conflict. Also, all client portfolios are managed following a team approach, with no
one employee responsible for any individual client’s portfolio. Finally, all employee outside
business activities require advanced notice and approval, with the goal of identifying and
determining how to mitigate conflicts identified (potentially including denying the request to
participate in the outside business activity).

                                                                            Dated March 31, 2026 | Page 9

                                                   PUNCH & ASSOCIATES | FORM ADV PART 2A

We have an incentive to encourage individual clients to rollover an employer retirement account
into a Punch & Associates-managed Individual Retirement Account (“IRA”), with the potential
for higher fees and lower liquidity. The decision of whether to rollover an employer retirement
account rests with the individual account owner, and we are committed to providing information
to help a client make a decision that is in that client’s overall best interests.

When we provide investment advice to clients regarding their retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the Employee
Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are
laws governing retirement accounts. The way we make money creates some conflicts with your
interests, so we operate under a special rule that requires us to act in your best interest and
not put our interest ahead of yours.

Our investment management agreement with the client determines the protocol the client or
we will follow in terminating accounts.