SIMS Investment Management LLC

Item 5: Fees and Compensation.
       Sims Investment Management, LLC charges a management fee for its services, which is
charged as a percentage of the assets under management, as a flat fee, or as an hourly rate. Sims
Investment Management, LLC will impose no start-up, closing, or penalty fees in connection with
an account; however, the custodian may charge some or all of these fees. Sims Investment
Management, LLC’s fees do not include variable life and annuity contracts, or hedge funds. Some
other types of assets would also be subject to additional advisory and other fees/expenses, which
are described in the prospectuses of those investments and paid to the investments, but
ultimately borne by the investor.

        The Assets Under Management Fee is calculated and collected quarterly in advance and
is based on the value of the account as of the last day of the prior quarter. At the end of each
quarter, SIM will calculate that quarter’s fee based on the average daily balance of the portfolio
throughout the prior billing period. SIM will compare the average daily balance fee to the fee
collected at the beginning of the period. If the average daily balance fee is less than the fee paid,
the difference will be credited towards the next quarter’s fees. If the average daily balance fee is
more than the fee paid, the difference will be charged towards the next quarter’s fees.

        The Assets Under Management Fee is based off asset value reported by the custodian to
our third-party calculation service by the custodian’s data delivery service; account activities
including distributions, trade-settle dates and cashflows, can cause the amounts reported by the
data delivery service and the custodial statement to differ.

       The quarterly fee is calculated by the assets multiplied by the annual fee divided by 365
(366 in a leap year) multiplied by the number of days in the period. If the Assets Under
Management Fee is a tiered fee schedule, the asset breakpoints will be applied on a blended
basis.

       At the onset of the relationship, SIM will begin charging for services on the day the assets
are available to manage or thereafter based on SIM’s discretion through the end of the current
quarter for the number of days the client was engaged with SIM.

      Upon termination, SIM will refund any prepaid fees based on the number of days
remaining in the pre-paid period.

SIM’s standard fee schedule is below.

                                     Assets                   AUM Fee

                                 $0 - $1,000,000                1.00%

                            $1,000,001 - $3,000,000             0.90%

                            $3,000,001 - $5,000,000             0.80%

                           $5,000,001 - $10,000,000             0.70%

                                  $10,000,001+                  0.60%

       Fees for comparable services may be available from other sources at a lower cost. These
fees are negotiable. The client will be charged separate fees for exchange, regulatory, and/or
third-party fees.

        All fees will be calculated in accordance with the agreed upon fee schedule between the
client and SIM. Unless other arrangements are made, fees are directly debited from clients’
accounts, and each client is required to provide the qualified custodian with written authorization
to deduct the fees described. The custodian sends the client a statement, at least quarterly,
indicating the amount disbursed from the account to SIM for the fees; SIM will not send a
statement with the fee information. SIM has internal controls that seek to verify that the
custodian is withdrawing fees accurately in accordance with the agreement, however, SIM
strongly encourages clients to independently verify the accuracy of the fee calculation, as the
custodian will not verify the calculation. If a client does not have sufficient cash in the account(s)
to cover the payment of fees, some or all of the securities held by the client will be liquidated in
order to pay the fees. SIM generally retains the right to amend our fee schedule with 30 days
prior written notice to the client.

       If SIM determines to utilize the services of SyntheticFi, they charge an Annual
Management fee of 0.50% of the loan amount which is calculated by the illustration below:
For example, if SyntheticFi manages a client’s $100,000 portfolio and trades a box spread as a
synthetic loan on January 1, 2023, that expires on December 31, 2023, with loan size (value-at-
expiration) of $50,000, the monthly management fee for July 2023 would be calculated as
$50,000*0.50%*(31/365) =$21.23, regardless of the balance withdrawn.

SyntheticFi shall be responsible for sending monthly client fee invoices via email. The fees will be
charged via client credit card on file at SyntheticFi.

       Some custodians of broker/dealers for the accounts of clients in Sims Investment
Management, LLC may charge maintenance or transaction fees that are separate from the
advisory fees charged by Sims Investment Management, LLC for its advisory services. The
custodian of the client’s account, which may be a mutual fund or insurance company, may
provide confirmations with each transaction and statements either monthly or quarterly. Any
transfer fees, transaction fees, redemption fees, sales loads, wiring fees, etc. charged against an
account are separate from the Sims Investment Management, LLC management fee, and will be
deducted from the account by the custodian.

        The hourly fee SIM charges for client consulting or project work is $250 per hour. The
Fixed fee SIM charges for client consulting or project work is in the range of $1,000 to $5,000.

       The rate for pension consulting services ranges from 0.25% to 0.60%. See chart below.

                                     Assets                  AUM Fee

                                 $0 - $100,000                  .60%
...

Item 7: Types of Clients
        Sims Investment Management, LLC clients are individuals, pension and profit-sharing
plans, corporations, and other business entities. The minimum account size is negotiable. There
is currently no maximum account size.