Steginsky Capital LLC

Item 5          Fees and Compensation

A. The client can determine to engage the Registrant to provide discretionary investment advisory services
   on a fee-only basis.

    INVESTMENT ADVISORY SERVICES
    If a client determines to engage the Registrant to provide discretionary investment advisory services on
    a fee-only basis, the Registrant’s annual investment advisory fee shall generally be based upon a
    percentage (%) of the market value and type of assets placed under the Registrant’s management on a
    tiered basis (between 0.50% and 1.00%) as follows:
          Market Value of Portfolio                                        % of Assets
          Initial $2,500,000                                               1.00%
          Additional Assets Between $2,500,001 and $25,000,000             0.75%
          Remaining Assets Above $25,000,000                               0.50%

    Custodian Charges-Additional Fees. When requested to recommend a broker-dealer/custodian for
    client accounts, Registrant generally recommends that Pershing serve as the broker-dealer/custodian
    for client investment management assets. Beginning October 1, 2025, Pershing will assess a quarterly
    asset-based custodial fee at the annual rate of 3 basis points (.03% of the account value), billed in
    advance, based on the value of the portfolio over the previous quarter. The value will be calculated
    from the average of the previous three-month end values for all assets in the account as determined by
    Pershing’s asset-based billing engine. FundVest, Alternatives, and Cash/Cash Equivalents shall be
    excluded from chargeable assets. 529 assets shall be excluded from billing. Fees will be pro-rated for
    accounts incepting or terminating during the billing period. Additional adjustments for deposits and
    withdrawals (flow billing) will apply. There will be a minimum quarterly charge of $30 per account,
    for accounts valued at $200 and above, and a $1,250 cap per account per quarter. Steginsky Capital
    receives no portion of this asset-based fee. In addition, account terminations will be charged $125 per
    account and foreign stock transfers will be charged $100 per item. There will no longer be commissions

    for trades nor charges such as wire fees. Of course, you always retain the option to choose your own
    custodian.

    Fee Dispersion. Registrant generally applies its fee schedule equally to all clients. However, Registrant
    reserves the right, in its sole discretion, to charge a lesser or higher investment advisory fee, charge a
    flat fee, waive appliable minimum asset or minimum fee levels, waive its fee entirely, or charge fee on
    a different interval, based upon certain criteria (i.e., anticipated future earning capacity, anticipated
    future additional assets, dollar amount of assets to be managed, related accounts, account composition,
    complexity of the engagement, anticipated services to be rendered, grandfathered fee schedules,
    employees and family members, courtesy accounts, competition, negotiations with client, etc.). Please
    Note: As result of the above, similarly situated clients could pay different fees. In addition, similar
    advisory services may be available from other investment advisers for similar or lower fees.

    Margin Billing. Clients may, at times, utilize margin on their own volition or obtain collateralized
    loans from unaffiliated third party financial institutions. The Registrant does not recommend, and
    recommends against the use of margin or collateralized loans. At the client’s insistence, the Firm will
    assist with the facilitation of margin or a collateralized loan. For clients who wish to utilize margin or
    collateralized loans, the Registrant generally bills its fee on the gross amount of managed assets in a
    client’s account, regardless of the amount of margin or collateralized loans held with the Registrant or
    third parties.

B. Clients may elect to have the Registrant’s advisory fees deducted from their custodial account. Both
   Registrant's Investment Advisory Agreement and the custodial/ clearing agreement may authorize the
   custodian to debit the account for the amount of the Registrant's investment advisory fee and to directly
   remit that management fee to the Registrant in compliance with regulatory procedures. In the limited
   event that the Registrant bills the client directly, payment is due upon receipt of the Registrant’s invoice.
   The Registrant shall deduct fees and/or bill clients quarterly in advance, based upon the market value
   of the assets on the last business day of the previous quarter. Registrant’s policy is to treat intra-quarter
   account additions and withdrawals equally unless indicated to the contrary on the Firm’s Investment
   Advisory Agreement executed by the client and will prorate fees on any contributions or withdrawals
   greater than 10% in any account during the quarter.

C. As discussed below, unless the client directs otherwise or an individual client’s circumstances require,
   the Registrant shall generally recommend that Pershing Advisor Solutions LLC, (“Pershing”) serve as
   the broker-dealer/custodian for client investment management assets. Broker-dealers such as Pershing
   charge brokerage commissions, transaction fees, or asset-based fees for executing certain securities
   transactions. Pershing charges an asset-based fee. In addition to Registrant’s investment management
   fee, brokerage commissions and/or transaction fees, clients will also incur, relative to all mutual fund
   and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other
   fund expenses). The fees charged by the applicable broker-dealer/custodian, and the charges imposed
   at the fund level, are in addition to Registrant’s investment advisory fees referenced in this Item 5.
...

Item 7           Types of Clients

    The Registrant’s clients shall generally include individuals, high net worth individuals, business
    entities, trusts, estates and charitable organizations. Registrant, in its discretion, may charge a lesser or
    higher investment advisory fee, charge a flat fee, waive appliable minimum asset or minimum fee
    levels, waive its fee entirely, or charge fee on a different interval, based upon certain criteria (i.e.,
    anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be
    managed, related accounts, account composition, complexity of the engagement, anticipated services
    to be rendered, grandfathered fee schedules, employees and family members, courtesy accounts,
    competition, negotiations with client, etc.). Please Note: As result of the above, similarly situated clients
    could pay different fees. In addition, similar advisory services may be available from other investment
    advisers for similar or lower fees.

INVESTING PHILOSOPHY
                        WE SEEK TO
“Volatility in the      INVEST . . .

stock market              WITH FIRST CLASS
                          ENTREPRENEURS
does not disturb       Their vision, boldness and passion for
us. In fact, we        excellence inspire organizations to
                       greatness. They are the lifeblood of
embrace                corporate growth which is the basis for the
                       creation of shareholder wealth.
volatility as one
of the reasons for        FOR THE LONG TERM
                       Corporate growth can be slow and uneven,
the wealth             yet the compounded effect over a long period
                       of time substantially rewards the patient
building power         investor.
of the market.”           WITH CONVICTION
                       We typically invest in between 6 to 8
                       companies. This intensely focused approach
                       assures us the highest level of investment
                       conviction and commitment.

                          IN VALUE
                       We favor stocks with meaningful cash flow and
                       when the shares are priced at a discount to
                       their true value. Our approach is intended to
                       minimize risk in weak markets without
                       compromising long term growth objectives.