Trinity Capital Management LLC

ITEM 5: FEES AND COMPENSATION
A. Compensation for Advisory Services

As described in greater detail below, TCM charges different types of fees dependent upon the
services being provided to the Client. The specific fees charged by TCM for its wealth
management services will be set forth in the Client’s MA as further specified below.

   1. Investment and Wealth Management Fees

For investment and wealth management services TCM generally charges a fee based upon a
percentage of assets under management, calculated on account values as of the close of business
on the last business day of the calendar quarter. TCM’s investment management fees are
assessed quarterly in arrears and based upon the following annual percentages:

                                                       Investment Management
              Assets Under Management
                                                       Annual Fee
              $0 - $500,000                            1.20%
              $500,001 - $2,000,0000                   0.80%
              $2,000,001 - $5,000,000                  0.60%
              $5,000,001 - $10,000,000                 0.50%
              Over $10,000,000                         0.45%

TCM requires a minimal annual fee of $3,000. TCM reserves the right to, in its sole discretion,
reduce, or waive the minimum fee requirement in its entirety.

Trinity Capital Management, LLC
Form ADV Part 2A

For purposes of calculating AUM, TCM will consider all investment management accounts
which constitute “household” of the Client’s assets. Typically, a Client’s household consists of
any spouse, parent, child, partner, or sibling who resides at the same mailing address as the
Client.

The Firm’s fees can be negotiated by TCM under certain circumstances, and at the sole
discretion and authority of TCM.

Should a Client open an account during the quarter, management fees will be prorated for assets
held for a partial quarter based on the number of days that the account was open during the
quarter. Additionally, the management fee payable on assets that are deposited into or withdrawn
from a Client’s account will be prorated based on the number of days remaining in the month. In
the event that TCM’s services are terminated mid-quarter, the quarterly fee shall be prorated
through the date of termination as defined in the Agreement and any earned, unpaid balance will
be immediately due and payable by the Client, and any prepaid unearned fees will be promptly
refunded to the Client.

Please note that the fees charged by investment company funds and the Client’s custodian are
exclusive of, and in addition to, TCM’s investment advisory fee. Please refer to Item 5.B below.

Pursuant to the Client’s written authorization in the MA, Clients provide TCM with authority to
invoice the Client’s custodian directly for payment of TCM’s fees. The custodian debits the fees
from the Client’s account(s) as soon as practicable following the last business day of each
calendar quarter and sends that amount to TCM.

Clients will receive a periodic (at least quarterly) account statement from the custodian,
reflecting among other things, any fees withdrawn by the custodian and paid to TCM. Clients are
urged to compare statements received by their custodian, with various reports sent by TCM. For
more information on the reports TCM provides to its Clients, please refer to Item 13 below.

   2. One Time or Periodic Planning Fees

In consideration of Advanced Planning services provided by TCM to non-Wealth Management
Clients, Clients will be assessed a flat fee usually ranging from $500 to $20,000 dependent on
the type, scope, and complexity of planning services offered. Factors that can affect pricing
include whether such services are for an individual or corporation, or if such services are
considered comprehensive, involve complex investment plans, and/or are individual
consultations regarding a Client’s financial affairs. TCM reserves the right, in its sole discretion,
to waive any or all fees associated with its Advanced Planning services.

At the sole discretion of the firm, fees for Advanced Planning services can be assessed fifty
percent (50%) prior to the commencement of services, with the remaining fifty percent (50%)
charged once the process is complete.

Trinity Capital Management, LLC
Form ADV Part 2A

For those Clients who are receiving Investment Management Services in addition to Advanced
Planning Services, TCM will typically waive any Advanced Planning fees so long as the Firm is
receiving an annual minimum fee of $10,000 for its Investment Management Services.

All fees, refund policies, termination provisions and other relevant disclosures as they relate to
advanced planning services are disclosed within the MA.

B. Other Fees and Expenses

Clients should understand that the fees described above do not include certain charges imposed
by third parties such as custodial fees and charges imposed directly by a mutual fund for fees or
expenses. Client assets can also be subject to transaction costs, retirement plan administration
fees (if applicable), deferred sales charges on mutual funds initially deposited in the account,
12b-1 fees, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other
fees and taxes on brokerage accounts and securities transactions.

Client assets invested in mutual funds will be subject to certain fees and expenses imposed
directly by mutual funds to their shareholders, which shall be described in each fund’s
prospectus. These fees will generally include a management fee, other fund expenses, and a
possible distribution fee. If the sponsor also imposes sales charges, a Client can pay an initial or
deferred sale or surrender charge, though TCM, as a policy, utilizes only no-load funds.

Such charges and fees incurred generally will be paid out of the assets in the account and are
...

ITEM 7: TYPES OF CLIENTS

TCM provides its wealth management services to individuals, retirement plans, trusts, estates,
charitable organizations, and/or small businesses (each a “Client” and collectively “Clients”).

TCM generally does not impose a minimum account size for opening and/or maintaining an
account. However, TCM typically does require a minimum annual fee. TCM’s minimum fee is
dependent upon the particular service(s) being performed. For those Clients who are only
receiving investment management services, TCM requires an annual fee of at least $3,000.
TCM’s minimum fee requirements are subject to negotiation and could vary depending upon
circumstances, including the scope of the services to be provided. TCM reserves the right to, in
its sole discretion, reduce, or waive the minimum fee requirement in its entirety. Please see Item
5 above for further details on fees.

As mentioned in Item 5 above, for those Clients who are receiving Investment Management
Services in addition to Advanced Planning Services, TCM will typically waive any Advanced
Planning fees so long as the Firm is receiving an annual minimum fee of $10,000 for its
Investment Management Services.

ERISA Clients

If a Client’s account is a pension or other employee benefit plan governed by the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”), TCM can be a fiduciary to the
plan. In providing our investment management services, the sole standard of care imposed upon
us is to act with the care, skill, prudence and diligence under the circumstances then prevailing
that a prudent man acting in a like capacity and familiar with such matters would use in the
conduct of an enterprise of a like character and with like aims. TCM will provide certain
required disclosures to the “responsible plan fiduciary” (as such term is defined in ERISA) in
accordance with Section 408(b) (2), regarding the services we provide and the direct and indirect
compensation we receive by such Clients. Generally, these disclosures are contained in this Form
ADV Part 2A, the Client agreement and/or in separate ERISA disclosure documents and are
designed to enable the ERISA plan’s fiduciary to: (1) determine the reasonableness of all
compensation received by TCM; (2) identify any potential conflicts of interests; and (3) satisfy
reporting and disclosure requirements to plan participants.

Compliance with PTE 2020-02

When we provide investment advice to our clients regarding a retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the Employee
Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws
governing retirement accounts. The way we make money creates some conflicts with our clients’
interests, so we operate under a special rule that requires us to act in your best interest and not
put our interest ahead of yours.

Trinity Capital Management, LLC
Form ADV Part 2A

Under this special rule’s provisions, we must:

  •   Meet a professional standard of care when making investment recommendations (give
      prudent advice);
  •   Never put our financial interests ahead of yours when making recommendations (give loyal
      advice);
  •   Avoid misleading statements about conflicts of interest, fees, and investments;
  •   Follow policies and procedures designed to ensure that we give advice that is in your best
      interest;
  •   Charge no more than is reasonable for our services; and
  •   Give you basic information about conflicts of interest.

TCM reserves the right to accept or decline a potential Client for any reason at its sole discretion.