Strategic Capital Allocation Group LLC

Fees and Compensation

SCA Group will provide investment advice to its employees and family members at no charge.

SCA Group will charge non-discretionary Clients an annual Investment Strategy Services fee based
upon the market value of assets designated by the Client to be a part of SCA Group’s services
(Designated Accounts). Invoices for such fees will be rendered quarterly in advance and will be
based upon the value of the assets in the accounts as of the last business day of the previous
calendar quarter, and including any additional cash or other assets committed by Client to SCA
Group. The net asset value of such assets will be shown on a report exhibit provided to a Client by
SCA Group and entitled “Market Value Breakdown and Asset Allocation Report.” Fees for new
accounts will be charged in advance, on a pro rata basis, at the inception of the account and
quarterly in advance thereafter. For purposes of determining the value of assets under
management, SCA Group may aggregate multiple accounts of an individual Client.

The fees paid to SCA Group do not include fees that may be charged by an investment or
investment manager, suggested by SCA Group and selected by a Client at its sole discretion, to
manage the Client’s assets. A Client should be aware that, in addition to SCA Group’s Investment
Strategy Services fees, he or she may incur, and will be responsible for, other fees and expenses,
including but not limited to, investment advisory fees charged by an investment manager, fees and
expenses of investment companies in which the Client is invested, margin interest and such other
commissions, fees, expenses and costs associated with securities transactions effected by or on
behalf of the Client’s Designated Accounts.

SCA Group reserves the right to modify the fee structure with written notice to the Client at least
ninety (90) days prior to the effective date of such modification, provided however that no
modification will be made during the initial one-year term of the Client’s agreement with SCA Group.
Services other than those set forth in the Client’s Letter of Engagement (“LOE”) with SCA Group
may require the payment of additional fees.

SCA Group’s Investment Strategy Services fees are:

                 Annual Asset-Based Fee (Paid quarterly, in advance | Daily for QMS)

                 Non-Discretionary Accounts:                                  50 Basis Points or ½%

                 QMS and other Discretionary Accounts:                        1.00%

The annual fee may be negotiated. A Client’s specific investment strategy services, including fees
and terms of the agreement between SCA Group and the Client, will be set detailed in the Client’s
Letter of Engagement (“LOE”) and will include applicable attachments or schedules.

Either the Client or SCA Group may terminate the agreement with ninety (90) days prior written
notice of intention to not renew the LOE and daily for QMS. When the LOE is terminated, any
unused fees that had been paid in advance by the Client will be pro-rated back to the Client in a
timely manner. Upon termination of the LOE by either the Client or SCA Group, SCA Group will not
be under any obligation to provide additional services or information to the Client. Termination of
the agreement will not affect the liabilities or obligations of either the Client or SCA Group under the
LOE arising prior to termination.

SCA Group Brochure – ADV Part 2
March 31, 2026

Types of Clients
Primarily, SCA Group Clients are institutions and high net worth individuals.

Minimum qualifying assets levels for non-discretionary Clients are typically:

$5,000,000 of investable funds for high net worth individuals

$50,000,000 of investable funds for institutions

Minimum qualifying assets levels for discretionary Clients, primarily QMS, are:

$250,000 for high net worth individuals

$1,000,000 for institutions

SCA Group Brochure – ADV Part 2
March 31, 2026

Methods of Analysis, Investment Strategies and Risk of Loss

It is important to be aware that different types of investments involve varying degrees of risk. Each
Client must be aware of these risks and be prepared to bear these risks.

It is the professional intent of SCA Group to attempt to design Client portfolios that maximize
diversification across relatively uncorrelated risks in a way that is compatible with a discretionary
investment strategy, such as QMS, or for a non-discretionary Client, each Client’s objectives and
tolerance to loss. Even so, there can be no assurance that any specific investment will either be
suitable or profitable for a Client’s portfolio and that there is always the possibility of loss of capital.
No Client or prospective Client should assume that any information presented in this document
serves as the receipt of, or a substitute for, personalized individual advice from SCA Group.

SCA Group’s patented and proprietary computer programs assist SCA to create hypothetical
portfolio allocations used to tailor suggested asset allocation for each Client. Each non-
discretionary Client may impose restrictions on investing in certain securities or types of securities.
Factors of qualitative and quantitative research (due diligence) are considered in such hypothetical
allocations. Due diligence may include, but is not limited to: historical returns of various asset
classes and investments, tax-sensitivity of the Client, expectations of return in a given investment,
the Client’s target return and likelihood achieving that return, the Client’s tolerance for losses, as
well as the Client’s exposure to losses in the event of extreme market conditions.

SCA Group’s patented asset allocation and risk management program is called by its brand name,
Quatrain. Quatrain is focused on managing risk at each Client’s level of tolerance to absolute
losses. SCA Group uses Quatrain to attempt to maximize diversification across relatively
uncorrelated risks, to minimize losses within a stated time horizon and release opportunity for
investment gains. None of these objectives can be assured and might not be met at all.

Quatrain relies upon reported investment return data supplied by an investment manager. While
this data is considered reliable, it may not be accurate and could lead to losses by the Client.
Computer malfunctions could also lead to allocation suggestions that, if implemented, could lead to
losses by the Client.

Another SCA Group patented program assists with SCA Group’s screening of potential investments
as part of its due diligence process. This program is called a Profiler. The Profiler uses the same
investment return data that is processed by Quatrain, and is subject to the same risks associated
with that data. The Profiler evaluates the return data to see how consistently a potential investment
can add positive returns with less volatility versus the worst absolute loss experienced by that
investment. The Profiler also can compare more than one investment at a time.

SCA Group Brochure – ADV Part 2
March 31, 2026