Spectrum Strategic Capital Management LLC

ITEM 5: FEES AND COMPENSATION

A. Compensation for Financial Planning Services

Spectrum will be compensated by fees for providing specific in-depth analysis of one or more
financial areas (“Financial Profiles”) or a complete financial assessment compiling all the available
financial profiles. As noted in Item 4 above, Financial Profiles include but are not limited to
investment planning, cash management, college planning, risk management, accumulation profile,
estate planning, retirement planning, and comprehensive planning. Fees for these services will be
billed at rates ranging from $100 to $425 per hour depending on whether services are performed
by a staff member or Firm partner, or on a fixed fee basis, as agreed upon with the client. Any
requested modifications by the client to a Financial Profile are generally billed at the same hourly
rate.

Spectrum’s hourly fee is negotiable at our sole discretion. Fees for financial planning services will
be billed and payable upon completion of the work.

Please refer to Item 4, above, for more information on what each plan entails.

In addition to financial planning fees charged to the client, Spectrum charges investment
management fees when a client chooses to implement the investment recommendations through
Spectrum. In situations where a prospective client has pre-determined to have us provide both
financial planning and investment management services, the financial planning fees are waived.

Also, as mentioned in Item 4, certain Spectrum advisory representatives also are licensed insurance
agents with various unaffiliated insurance companies and the firm’s affiliated insurance agency,
Spectrum Insurance Services, LLC. When the advisory representatives implement insurance
transactions in this separate capacity, they earn commissions and/or other fees. This creates
conflicts of interest. However, clients are under no obligation to implement any recommendations
made by Spectrum and always have the right to select any advisory firm, brokerage firm,
insurance agency, or similar sales agency or representative to implement any or all of our
recommendations. For more information on Spectrum’s insurance affiliations, please refer to Item
10 below.

Spectrum Strategic Capital Management, LLC                                      June 26, 2026
Form ADV Part 2A

    1. General Information on Financial Planning Fees

Clients may choose to use the financial planning profiles individually or in combination and are
not restricted to only financial planning services. All fees are negotiable at the sole discretion of
Spectrum. Clients choosing to receive only financial planning services, will be required to enter
into a Client Agreement and pay a financial planning fee, as described above. The client or
Spectrum can terminate the Client Agreement at any time with 30 days written notice to the other.

If the client cancels the Client Agreement after Spectrum has begun the financial planning services
requested, the client shall be charged for the services completed. In all matters, Spectrum’s
financial planning services are analytical and advisory only and do not include legal or tax advice.
We will work with your legal, accounting, insurance or other professional advisers, as needed to
ensure the coordination of all pieces involved in the financial planning and/or estate planning
process.

All fees paid to Spectrum for investment management or financial planning services are separate
and distinct from any fees charged by third parties, including but not limited to brokers,
custodians, and the fees and expenses charged by mutual funds and ETFs to their shareholders or
fees charged by other investments, including Private Funds. Please refer to Item 5.C below for
further information on additional fees charged by third parties.

B. Compensation for Investment Management Services

    1. Investment Management Services Strategy and Enhanced Index Strategy

Upon initial opening of a managed account, Spectrum’s investment management fees for accounts
to be invested in the Investment Management Services Strategy or the Enhanced Index Strategy
will be charged in advance based on the value of the account assets and the number of days
remaining in the quarter. These fees are due and payable upon the initial opening of a managed
account and will be deducted from the account assets, as outlined in the Client Agreement.

Thereafter, unless otherwise negotiated and memorialized in the Client Agreement, Spectrum
charges an annualized quarterly management fee (i.e., determined quarterly based on a 365-day
calendar) 3 for accounts invested in either strategy, which is billed in advance and based on the fair
market value of a client’s assets under management (“AUM”) (including cash, cash equivalents
and margin balance) at the end of the preceding calendar quarter. . The quarterly management fee
is calculated by Spectrum and based on the fair market value of a client’s account(s) as of the close
of business on the last business day of the immediately preceding calendar quarter, as reflected in
Black Diamond.

If a client has a managed account invested in either the Investment Management Services Strategy
or the Enhanced Index Strategy that is a margin account, our investment management fee will be
based on the full value of the account’s assets under management without regard to the amount of
margin debt on the account. Clients need to be aware that buying investments using margin

  The quarterly fee percentage will vary by quarter as it is based on the number of calendar days in a billing period;
however, the total quarterly percentages for each calendar year will never exceed the annual fee percentage charged to
a client.

Spectrum Strategic Capital Management, LLC                                      June 26, 2026
Form ADV Part 2A

increases the amount of fees paid to us. In addition, a client with a margin account is charged
...

ITEM 7: TYPES OF CLIENTS
A. Description

Spectrum provides advisory services primarily to individuals and high net worth individuals, as
well as to pension and profit-sharing plans, charitable organizations, and corporations or other
business entities.

B. Conditions for Managing Accounts

For a client account invested in the Investment Management Services Strategy with an investment
objective allocation of Ultra-Conservative, Conservative, Moderate, Moderate Growth, Growth or
Aggressive Growth strategy, the minimum initial investment is $200,000. For a client account
invested in Enhanced Index Strategy with an investment objective allocation of Income, Growth
and Income, or Capital Appreciation, the minimum initial investment is $20,000. For a client
account invested in the Unconstrained Alpha+ Strategy, the minimum initial investment is
$100,000. We have in the past and may in the future, at our discretion, choose to aggregate other
accounts of the client to meet this minimum, or make other exceptions as appropriate in the
circumstances. The above minimums can vary and have in the past and may in the future be
waived in our sole discretion.

When Spectrum provides investment advice to a client, we are deemed a fiduciary under certain
federal regulations, and 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 the firm makes money creates conflicts of interest; however, as a fiduciary,
Spectrum and our supervised persons are required to always act in our clients’ best interests, which
means we must, at a minimum take the following steps:

   •   Meet a professional standard of loyalty and care when making investment
       recommendations.
   •   Always put our clients’ interests ahead of our own when making recommendations and
       providing services.
   •   Disclose all conflicts of interest and how the Firm addresses such conflicts.
   •   Adopt and follow policies and procedures designed to help ensure that we give advice and
       provide services that remain in each client’s best interest.
   •   Charge an advisory fee that is reasonable for our services.
   •   Not provide, or withhold, any information that could render our advice and/or services
       misleading.

If a client’s account is a pension or other employee benefit plan governed by the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”), Spectrum may be a fiduciary to
the plan. In providing our investment management services, the sole standard of care imposed
upon us is to act with the care, skill, prudence and diligence under the circumstances then
prevailing that a prudent man acting in a like capacity and familiar with such matters would use in
the conduct of an enterprise of a like character and with like aims. Spectrum will provide certain

Spectrum Strategic Capital Management, LLC                           June 26, 2026
Form ADV Part 2A

required disclosures to the “responsible plan fiduciary” (as such term is defined in ERISA) in
accordance with Section 408(b)(2), regarding the services we provide and the direct and indirect
compensation we receive by such clients. Generally, these disclosures are contained in this Form
ADV Part 2A, the Client Agreement and/or in separate ERISA disclosure documents and are
designed to enable the ERISA plan’s fiduciary to: (1) determine the reasonableness of all
compensation received by Spectrum; (2) identify any potential conflicts of interests; and (3) satisfy
reporting and disclosure requirements to plan participants.