Royal Palms Capital LLC

ITEM 5: FEES AND COMPENSATION

          RPC charges fees based on a percentage of assets under management, hourly charges, and fixed
          fees, depending on the types of advisory services to be provided. The specific fees charged by
          RPC for its advisory services will be set forth in each client’s written agreement with RPC.
          Although RPC believes its advisory fees are competitive, clients should be aware that lower fees
          for comparable services may be available from other sources.

          A. Fee Schedule

               1. Investment Supervisory Services

          For investment supervisory services RPC’s compensation is derived from a fee based upon a
          percentage of the client’s assets under management. The compensation method is explained and
          agreed with the clients in advance before any services are rendered. The compensation for our
          services, which include developing and implementing an investment policy and objectives,
          formulating quantitatively driven asset allocation analysis and recommendation, monitoring a
          client’s investment results is as follows:

               Accounts below $50,000.
                   Accounts below $50,000 are subject to a minimum fee of $50 per quarter. The annual fee
                  charged to clients will never exceed 3.00% of total assets under management.

               RPC Managed Portfolios
                  (Portfolios containing any combination of stocks, bonds, and/or mutual funds, separately
                 managed accounts)

Royal Palms Capital, LLC
Form ADV Part 2A                                                                                  June 29, 2026

                                          Assets Under Management         Fee
                                              The first $250,000        1.375%
                                               the next $750,000         1.20%

                                             the next $3,000,000         1.00%
                                             the next $6,000,000         0.75%

                                               Over $10,000,000          0.50%

               Fixed Income Only Portfolio, Mutual Funds Only Third Party Separate Outside Manager
               Accounts

                                         Assets Under Management          Fee
                                            The first $10,000,000       0.50%
                                              Over $10,000,000           0.35%

          The amount of the fee is negotiated on a case-by-case basis with the client and is determined
          based upon a number of factors including the amount of work involved, the assets placed under
          management, and the attention needed to manage the account. Fees for clients are billed
          quarterly in advance and are calculated by multiplying one fourth of the annual rate based on a
          percentage of the client’s assets under management as valued by the qualified custodian at the
          end of the calendar quarter. For purposes of fee billing, RPC will aggregate household assets to
          determine the client’s AUM. Here, a household is defined as husband, wife or partner, and son or
          daughter, etc.) living in the same residence, who execute the same investment advisory
          agreement and denote which accounts they desire to be managed by RPC.

          Investment advisory services begin with the effective date of the Agreement, which is the date
          the client signs the Investment Advisory Agreement. For that calendar quarter, fees will be
          adjusted pro rata based upon the number of calendar days remaining in the calendar quarter that
          the Agreement was effective. Fees will generally be deducted directly from the client’s
          brokerage account pursuant to the client’s written agreement with RPC.

          The minimum size for a new account in an RPC Managed Portfolio is $1,000,000 unless certain
          conditions are met. A minimum account size of $1,000,000 can be achieved by aggregating
          separate accounts of individual Clients within the same household (as that term is defined
          above). In addition, should a long-standing client refer a prospective client to RPC, the Firm
          may accept accounts with less than $1,000,000 in assets under management. Should the market
          value of the Account fall below the stated minimum, RPC shall have the right to require that
          additional monies or securities be deposited to bring the Account value up to the required
          minimum or to close the Account. The minimum account level may be waived at the sole
          discretion of RPC.

Royal Palms Capital, LLC
Form ADV Part 2A                                                                                      June 29, 2026

          For purposes of fee billing, RPC will aggregate household assets to determine the client’s AUM.
          RPCs Investment Advisory Agreement may be terminated upon 30 days written notice by either
          party. The client is responsible to pay for services rendered until the effective date of termination.
          The client can cancel the Agreement without penalty within the first five days after signing of the
          Agreement.

          Clients should consider verifying the accuracy of the fee calculation submitted to the custodian
          by RPC, as the custodian will not determine whether the fee has been properly calculated. Lower
          fees for comparable services may be available from other sources.

               2. Investment Consulting Services

          Fees for investment consulting services are based on RPC’s standard rate of $350 per hour. Such
          fees shall be mutually agreed upon by the client and RPC and shall be due and payable when
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ITEM 7: TYPES OF CLIENTS

          A. Description

          RPC generally provides investment advice to individuals, pension and profit-sharing plans,
          trusts, estates, corporations, and other business entities.

          B. Conditions for Managing Accounts

          Generally, the minimum dollar value of assets required to set up an investment advisory account
          is $1,000,000. However, this sum can be achieved by aggregating separate accounts of individual
          clients within the same household as that term is defined in Item 5 of this Brochure. The account
          minimum may be waived at the sole discretion
          of RPC. Other exceptions will apply to employees of RPC and their relatives, or relatives of
          existing clients. Please note that accounts with small asset balances may pay a higher annual fee
          than those normally charged by other investment advisors. Accounts below $50,000 are subject
          to a minimum annualized fee of $1000 or at the negotiated rate per quarter or a $50 minimum per quarter.
          Furthermore, in cases of referrals by long standing clients, effective fees may be applied on a relationship
          level and not individual account size level.

Royal Palms Capital, LLC
Form ADV Part 2A                                                                                       June 29, 2026

          RPC charges a minimum fee of $25 per quarter for the management of variable annuities.