Strategas Asset Management LLC

Item 5. Fees and Compensation                                internal fees and expenses that are borne either
           SAM’s fee depends on the type of service the client          directly or indirectly by their holders, including a
           receives. In addition to SAM’s fees discussed                client. These fees and expenses may include
           herein, clients are or may be responsible for                investment management fees, distribution (12b-1)
           bearing or paying the costs of all:                          fees, shareholder servicing fees, transfer agency
                                                                        fees, networking fees, accounting fees, marketing
           • commissions,     markups,      markdowns,       and        support payments, administration fees, custody
             spreads charged by broker-dealers that buy                 fees, expense reimbursements, and expenses
             securities from, or sell securities to, the client’s       associated with executing securities transactions
             account (such costs may be inherently reflected            for the investment product’s portfolio (“ongoing

Strategas Asset Management, LLC                                                           Strategas Asset Management, LLC Brochure
52 Vanderbilt Avenue, 19th Floor, New York, NY 10017                                                               Rev. 7/17/2026
(855) 273-7227

           operating expenses”). These ongoing operating               quarter-end, SAM refunds automatically a pro rata
           expenses are separate from, and in addition to,             share of the fee on a per diem basis.
           SAM’s fee. As a result of making investments in
           these types of products, a client should be aware           Portfolio Management Services
           that the client is paying multiple layers of fees and       For Portfolio Management Services, the terms of
           expenses on the amount of the client’s assets so            the client’s contracts with the Platform and/or SAM
           invested—the ongoing operating expenses and                 describe the fee arrangements.
           SAM’s fee. A client is also responsible for any
           redemption fees or similar fees that the fund or its
                                                                       SAM typically charges a fee for Portfolio
           sponsor may impose on the client. A client should
                                                                       Management Services on a quarterly basis at an
           review the prospectus or other applicable offering
                                                                       annual rate of 0.50% of the value of the client
           documents for each investment fund in which the
                                                                       assets in the account managed by SAM. However,
           client invests for further information.
                                                                       SAM’s fee is negotiable, and SAM has clients who
                                                                       pay less than that rate, including clients who
           All fees paid to SAM for services are separate and          retained SAM for Portfolio Management Services
           distinct from these fees. Please refer to Item 10 for       prior to November 1, 2018, and clients who retain
           information regarding SAM’s material relationships          SAM to provide Portfolio Management Services on
           and potential conflicts of interest. Please refer to        a sub-advisory basis through Platforms. Generally,
           Item 12 for information regarding brokerage                 SAM’s fee is deducted and paid directly out of the
           practices.                                                  client’s account.

           Separately Managed Accounts                                 When SAM’s quarterly fee is paid in advance, the
           Model Delivery Services                                     fee is typically calculated on the value of the
           Unless otherwise agreed, SAM charges its fees               client’s account as of the last day of the prior
           quarterly in arrears for Model Delivery Services            quarter. When SAM’s quarterly fee is paid in
           clients. Typically, SAM’s fee is at an annual rate          arrears it is typically calculated on the value of the
           ranging from 10 to 35 basis points, i.e., 0.10% to          client’s account as of the last day of the quarter
           0.35% for equity and balanced portfolios and                that most recently ended. When a client first
           0.10% to 0.25% for fixed income portfolios, on the          establishes an account during a calendar quarter
           assets invested in the selected Model Portfolio.            and SAM’s fee is payable in advance, the fee will
           SAM’s fee is negotiable.                                    be calculated based on the value of the account at
                                                                       the time SAM begins to provide Portfolio
           Under a Model Delivery Services arrangement, a              Management Services and the number of days
           client agrees to pay SAM a fee based on the market          remaining until the end of the quarter. When a
           value of the total underlying client assets invested        client first establishes an account during a calendar
           on the last trading day of each quarter in                  quarter and SAM’s fee is payable in arrears, SAM’s
           accordance with the selected Model Portfolio(s)             fee for the first quarterly period will be calculated
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