Sterling Capital Management LLC

Item 5 – Fees and Compensation

Fees – How and When Clients are Billed
Sterling is compensated for providing investment management services by charging an investment management
fee. Generally, the investment management fee is based on an annual rate on total AUM or assets under
advisement (“AUA”) for Model Programs or other non-discretionary services. Occasionally, Sterling may consult on
a small percentage of portfolios that are not actively managed by Sterling. Fixed fees may be set when the amount
of work involved is not directly related to the AUM or AUA. Sterling does not receive compensation from the sale of
securities or other investment products.
Performance-based investment management fees may be available where applicable by law. These fee schedules
are customized and individually negotiated. Please refer to Item 6 – Performance-Based Fees and Side-by-Side
Management.

Fees and minimum account sizes may vary or be negotiable depending upon a number of factors including, but not
limited to: the type of client; products or services; the complexity of the client’s situation; the composition of the

Sterling Capital Management              Form ADV Brochure | 31 March 2026                                             8

client’s account; the potential for additional account deposits; the nature, longevity and size of the overall client
relationship; the total amount of assets under management for the client; and other business considerations. The
negotiations may result in a reduced, higher, or fixed fee.

From time to time, Sterling may enter into arrangements with third parties who introduce prospective clients to us.
Clients introduced through these third parties may be offered a preferred or negotiated fee schedule that is lower
than the firm’s standard advisory fee charged to other clients receiving similar services. The preferred fee schedule
reflects the nature of the relationship and the scope of services associated with such clients.

Fees are generally billed monthly and quarterly, in arrears (though certain clients will be billed in advance if specified
in their written agreement with Sterling), depending on the nature and circumstances of the client and services
selected. Clients may elect to be billed directly for fees or to authorize Sterling to debit fees from the client’s
managed account(s). In some instances, clients calculate their own fee and initiate payment to Sterling. Sterling’s
investment management agreement may be cancelled by either party upon written notice. If a client account is
terminated prior to the end of a billing cycle, any investment management fees paid in advance may be refunded
on a pro-rated basis. For clients that pay in arrears, in the event of a termination, any earned but unpaid fees will
be billed on a pro-rata basis payable and due to Sterling.

Unless otherwise provided in an investment management agreement, when Sterling is responsible for calculating
the fees owed by a client, we will calculate the fee according to the market value of AUM in the account on our
portfolio accounting system(s), which may include securities for which current market prices are not available,
securities for which Sterling elects to override the market price provided by a third party, or securities for which
pending portfolio activities have not yet been fully processed. A conflict of interest exists when Sterling calculates
fees based on securities that we have determined the market value for as Sterling may be incentivized to apply a
higher valuation. Sterling has adopted valuation policies and procedures that are designed to value securities fairly,
mitigating this conflict of interest. Due to differences in securities’ valuations and/or pending portfolio activities, a
client account’s AUM calculated by Sterling may differ from the account’s AUM reported by the client’s custodian.

Sterling reserves the right to change our standard fee schedules and absent contractual provisions to the contrary,
is not required to change the fee schedules of existing clients to match any such updated fee schedules, even if
such updated fee schedules would be more advantageous to the client. Therefore, client fees may vary based on
a historical fee schedule or a different negotiated fee based on the time the contract was executed between the
client and Sterling. Sterling may, at our sole discretion, offer certain clients more advantageous fee schedules than
those offered to other clients for similar services provided.

Additional Fees and Costs
There are a number of other fees that can be associated with holding and investing in securities. In addition to the
investment management fees paid to Sterling, clients may also incur certain charges imposed by other third parties,
such as broker-dealers, custodians, trust companies, banks, and other financial institutions. These additional
charges may include brokerage commissions, transaction fees, custodial fees, fees charged by other managers,
margin costs, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s
prospectus or offering document (e.g., fund management fees and other fund expenses), deferred sales charges,
odd-lot differentials, transfer taxes, wire transfer, and electronic fund fees, and other fees and taxes on brokerage
accounts and securities transactions.

Fees for Fund Management
Sterling may include mutual funds, ETFs, and other pooled vehicles (CTFs, CIFs, etc.) in our investment strategies;
these funds also charge operating expenses, which are disclosed as “other expenses” in the fund’s prospectus or
offering document. When Sterling purchases a mutual fund in a client portfolio, Sterling, on a best-efforts basis,
selects the lowest cost share class of such mutual fund in which the client is eligible to invest at the time of initial
purchase. Sterling periodically reviews advisory client mutual fund holdings to determine if a lower cost mutual fund
...

Item 7 – Types of Clients

Sterling provides investment management services to a diversified group of clients including, but not limited to,
individuals, high net worth individuals, trusts, estates, banking or thrift institutions, affiliated and non-affiliated
investment companies (e.g., mutual funds and ETFs) and other pooled investment products (e.g., CTFs, CIFs and
private investment funds), investment advisers, foundations, endowments, charitable organizations, corporations
and other business entities, insurance companies, state and municipal government entities, churches, and affiliated
and non-affiliated Wrap Programs. In addition, Sterling also provides investment management services to retirement
plans including 401(k) plans, 403(b) plans, pensions, and profit-sharing plans, non-qualified plans or other
retirement plan types not listed.

Sterling provides investment management services to certain of its affiliates pursuant to investment management
agreements. Sterling may manage the investment accounts of employees and their family members, or Sterling
may manage an Affiliated Fund held by, or serve as an advisor to a Wrap Program used by, employees and their
family members.

Portfolio minimums vary by type of client (e.g., wealth management, institutional), investment type (e.g., fixed,
equity), and investment strategy (e.g., small cap, mid cap, balanced, short term fixed, intermediate fixed). Wrap
program sponsors set their own account size minimums and, in the case of Affiliated Funds and other pooled
vehicles, the minimum amount investors must invest is set forth in each fund’s prospectus or relevant offering
document and varies from fund to fund depending on the particular investment product.

For specific portfolio minimums, please refer to Appendix A – Sterling’s Fee Schedule.

Sterling Capital Management               Form ADV Brochure | 31 March 2026                                               11