Thirtynorth Investments LLC

Item 5 Fees and Compensation
The vast majority of the Company’s revenues          Internal Expense Ratios – Mutual funds, ETFs,
are from fees paid directly by our clients. which    and ETNs charge investors an internal expense
is explained below. We do not earn sales             ratio to pay for the management and
commissions or payouts from the investment           administration of the fund. Expense ratios are
products we recommend in our discretionary           deducted daily and are reflected in the NAV
portfolios.                                          (Net Asset Value) price of the funds. We
                                                     recognize that keeping costs low is imperative
1. Discretionary Investment Management Fee           to long-term investment success. The Company
   Schedule                                          seeks to identify investments with low overall
                                                     expense ratios for our portfolios.
  Account Balance                  Annual Fee
  First $499,999.99                1.25%             Transaction Fees – In some instances, our
  $500,000-$2,500,000              1.00%
                                                     custodians charge small transaction fees for
  Greater than $2,500,000          0.50%
                                                     buying and selling investments. Our investment
                                                     strategy does not lead to a large volume of
For accounts open prior to 3/1/2026 pre-
                                                     trading in client accounts, and we expect the
existing fee schedules may still apply. The
                                                     trading costs in client accounts to remain
Company may choose to charge a reduced rate
                                                     minimal.
based upon circumstances.
                                                     For smaller accounts, we have identified Non-
                                                     Transaction Fee (NTF) investment vehicles to
2. Alignment, by ThirtyNorth Fee Schedule
                                                     further reduce total transaction costs for
  Account Balance                  Annual Fee
                                                     clients. NTF investments charge higher internal
  First $499,999.99                1.50%             expense ratios to compensate the custodian for
  $500,000 - $2,500,000            1.25%             the loss of the transaction fee. We perform a
  Greater then $2,500,000          0.75%             cost/benefit analysis to determine whether the
                                                     client should pay the transaction fee or utilize
                                                     the NTF investment option.
For accounts open prior to 3/1/2026 pre-             .
existing fee schedules may still apply. The
Company may choose to charge a reduced rate          401(k) and 403(b) Plans
based upon circumstances.                            The charges for 401(k) and 403(b) accounts
                                                     vary by plan. In general, the higher the total
Fees are usually deducted monthly, and in some       plan’s assets, the lower the asset-based fee
cases quarterly, from clients’ accounts. Fees are    charged by the Company. Record-Keepers,
calculated based on the account value on the         Administrators, and Custodians charge fees
last business day of the prior month.                in addition to the Company's and some of
                                                     them share in the annual expenses charged

for each investment option.                           before they have sufficient assets set aside for
                                                      ongoing expenses, upcoming large purchases,
Other                                                 and emergencies.
Regardless of where an account is held for a
client, the Company is not compensated                Retirement Plans – The Company serves as
based on the expenses of an investment                investment advisor for qualified retirement
option. The Company is only compensated               plans such as 401(k)s, 403(b)s, and profit
for managing accounts directly by the client          sharing plans. As an independently owned
and our incentive is to grow and protect              Company, we have the ability to work with any
assets since our fee is based on the balance of       record-keeper, custodian, or third-party
client accounts.                                      administrator, and we help our clients select
                                                      these providers. We do not have a stated
We are able to deduct our fee from most               minimum for retirement plan clients and will
accounts on a monthly basis, and in most cases,       accept new start-up plans in some cases.
fees are charged in advance. The Company's
fees are not charged until the beginning of the       Institutions – The Company provides advisory
month. In some cases, new accounts opened             services to institutions such as non-profit
during the month will be billed a partial fee for     organizations , private foundations and
the portion of the month that we manage the           endowments.
account. There are no refunds of fees charged if
an account is closed in the same month a fee is
charged.                                              Item 8 Method of Analysis, Investment
                                                      Strategies, and Risk of Loss

Item 7 Types of Clients
ThirtyNorth Investments, LLC works with the           Mutual Funds, ETFs
following types of clients:                           Mutual funds and exchange traded funds (ETFs)
                                                      are professionally managed collective
Individuals and High Net Worth Individuals –          investment systems that pool money from
including Individual Retirement Accounts (IRAs),      many investors and invest in stocks, bonds,
trusts, and estates. We have no stated                short-term money market instruments, other
minimum account size for individual accounts,         mutual funds, other securities or any
but we discourage individuals from investing          combination thereof. The fund will have a

manager that trades the fund's investments in      prepared to bear such loss.
accordance with the fund's investment
objective. While mutual funds and ETFs             Item 9 Disciplinary Information
generally provide diversification, risks can be    Neither the Company nor any of its
significantly increased if the fund is             principals or employees has any
concentrated in a particular sector of the         disciplinary history to report.
market, primarily invests in small cap or
speculative companies, uses leverage (i.e.,        Item 10 Other Financial Industry Activities and
borrows money) to a significant degree, or         Affiliations
concentrates in a particular type of security      Suzanne T. Mestayer is a CPA - inactive.
(i.e., equities) rather than balancing the fund    Fritz Gomila is a member of GF Group, LLC, a
with different types of securities. Exchange       holding company with investments in real
traded funds differ from mutual funds since        estate and a private equity fund but he receives
they can be bought and sold throughout the         no compensation other than growth of value in
day like stock and their price can fluctuate       investment.
throughout the day. The returns on mutual
funds and ETFs can be reduced by the costs to
manage the funds. Also, some mutual funds are      Item 11 Code of Ethics, Participation or Interest
“no load” and charge no fee to buy into, or sell   in Client Transactions, and Personal Trading
out of, the fund, and other types of mutual
funds do charge such fees that can also reduce     Pursuant to SEC Rule 204A-1, the Company has
returns. Mutual funds can also be “closed end”     adopted a Code of Ethics written to assist with
or “open end”. So-called “open end” mutual         maintaining an atmosphere of disclosure to
funds continue to allow in new investors           avoid any potential conflicts of interests with
indefinitely whereas “closed end” funds have a     clients and compliance with applicable
fixed number of shares to sell that can limit      securities laws. The Company reviews personal
their availability to new investors.               securities transactions of all staff members and
                                                   prohibits many transactions that could
Structured notes                                   potentially create an appearance of a conflict of
Structured notes are senior, unsecured debt        interest with clients. Staff and members of the
instruments of the issuing financial institution   company have their personal investments
and bear the full credit risk of the issuer in     aligned with the strategies utilized for our
addition to the risks of the underlying            clients. The Company encourages any new hires
investments. Although structured notes track       to open accounts with the Company. If a staff
an underlying basket of investments, their         member of the Company has an account that is
performance may differ significantly. Structured   not managed by the Company, such account is
notes have a maturity date, but may not return     monitored by the Chief Compliance Officer. The
the full principal. Structured notes are not       Company’s Code of Ethics is available to all
considered liquid investments.                     clients and prospective clients for their review
                                                   upon request.
All of the investment portfolios we manage for
clients involve the potential risk of loss of      Item 12 Brokerage Practices
principal. ThirtyNorth Investments, LLC strives    As mentioned above in Item 5, we generally
to determine the appropriate level of              recommend that individual clients utilize the
investment risk in a client’s portfolio by         brokerage and clearing services of Schwab for
assessing the client’s objectives, time horizon,   investment management accounts.
and tolerance for risk. Investing in securities    Factors which the Company considers in
bears the risk of loss. Clients should be          recommending Schwab or any other broker-

dealer to clients, include their respective          not pay any fees to Schwab for the Additional
financial strength, reputation, execution,           Services. Schwab and ThirtyNorth Investments,
pricing, research and service. The commissions       LLC have entered into a separate agreement
and/or transaction fees charged by Schwab may        (“Additional Services Addendum”) to govern the
be higher or lower than those charged by other       terms of the provision of the Additional
Financial Institutions.                              Services. Our receipt of Additional Services
                                                     raises potential conflicts of interest. In providing
The client may direct the Company in writing to      Additional Services to us, Schwab most likely
use a particular Financial Institution to execute    considers the amount and profitability to
some or all transactions for the client. In that     Schwab of the assets in, and trades placed for,
case, the client will negotiate terms and            our Client accounts maintained with Schwab.
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