SMA Capital LLC

Item 5 Fees and Compensation

Management and Performance Fee

The calculation and payment of management and performance fees for separately managed accounts
are governed by investment management agreements with the account owners. Depending on the
arrangement with the client, either we send a calculation for the client's approval, or the client (or the
client's administrator) calculates the fees, which we then confirm. These fees are approved and paid by
the account owners.

SMA Capital's fees are exclusive of brokerage commissions, transaction fees, custodial fees, and other
related costs and expenses, which are incurred by SMA Capital clients. Each client is subject to fees,
allocations, and expenses as described in their specific investment management agreement. For
brokerage practices, see Item 12 of this Brochure.

The performance allocations and performance fees are charged in compliance with Rule 205-3 of the
Investment Advisers Act of 1940, as amended (the “Advisers Act”), whereby each investor may be a
“qualified client”.

Expenses

Clients generally bear investment expenses, which we reasonably determine to be related to the
investment of the separately managed account. These expenses include, but are not limited to,
brokerage commissions, expenses related to short sales, clearing and settlement charges, custodial
fees, bank service fees, interest expenses, and the cost of investigating actual or potential
investments. Additional costs may include expenses related to trade execution and management
systems, compliance, risk and portfolio systems, integration and data transfer connectivity costs,
research products and services, professional fees, third-party research products and services,
subscriptions, and publications regarding investments. Clients also bear expenses related to
registration and compliance obligations, legal expenses, accounting expenses, auditing and tax
preparation expenses, directors and officers insurance, organizational expenses, and extraordinary
expenses. Furthermore, SMA Capital may invest a portion of certain clients' capital in exchange-
traded funds, and investors will indirectly incur similar fees and expenses for these investments.

Item 7 Types of Clients

As mentioned in Item 4, SMA Capital advises separately managed accounts for institutional investors.
SMA Capital targets clients with a minimum account size of $25,000,000. However, SMA Capital
reserves the right to accept accounts of a lesser amount.