Twin Focus Capital Partners LLC

ITEM 5. FEES AND COMPENSATION
TwinFocus offers its services on an annual fee basis which includes hourly and/or fixed fees, as well as
fees based upon assets under management and/or the performance of a Client’s investment portfolio. In
this connection, TwinFocus acknowledges Rule 205-3 of the Advisers Act (“Rule”) which permits
investment advisers to receive performance-based compensation only when a Client is a “qualified client”
for purposes of the Rule.

Types of Annual Management Annual Fees
Prior to engaging TwinFocus, a Client is required to enter into a written advisory and investment
management agreement with TwinFocus, setting forth, among other things, the terms, conditions,

Form ADV Part 2A                                                                                 Disclosure Brochure: March 2026

specific services, and Wealth Management and Family Office Advisory fees for each Client engagement.
These agreements are referred to as Client FOAAs throughout this Form ADV Disclosure Brochure.

TwinFocus structures annual management fees in Client agreements using different methodologies,
including:

    a)   fixed annual fees
    b)   annual asset-based fees
    c)   performance-based fees
    d)   fees based on hourly rates and/or
    e)   combination of those types of fees, billed quarterly in advance, for Wealth Management and/or
         Family Office Management services.

Additionally, with respect to fixed annual fees, TwinFocus in most situations indexes the annual flat fee to
some percentage increase that is clearly defined in the Client FOAA (i.e., under Exhibit C to such Client
FOAA) to take into consideration annual inflation adjustments. 7 In certain engagements, annual fees can
also be determined by a hybrid approach where the annual fee is equal to the greater of a a) fixed annual
fee and b) an annual asset-based fee.

These fees are negotiable, but generally range from $100,000 to $2,000,000 on an annual basis, and/or
from $450 to $1,800 on an hourly rate basis, depending upon the level and scope of the services and the
professional(s) providing the Wealth Management and/or the Family Office Management services.

As stated above, TwinFocus also enters into agreements with Clients based on performance fees in
accordance with SEC rules and regulations, typically with high watermarks and preferred hurdle returns
for Clients.

TwinFocus’ annual fees are exclusive of and in addition to product-related fees, brokerage commissions,
transaction fees, and other related costs and expenses which are incurred by a Client directly, all of which
are clearly detailed in each Client’s FOAA.

In some instances, TwinFocus, in its sole discretion, charges a lesser or deferred/accrued management
fee based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional
assets, anticipated monetization events, dollar amount of assets to be managed, related accounts,
account composition, pre-existing client, strategic relationships, account retention, pro bono activities,
etc.).

Annual Fees | Timing, Invoicing & Calculations
TwinFocus Clients receive invoices for their quarterly fees as part of their regular client reporting packages.
Most quarterly fees for those Clients that are on flat fee arrangements are either paid at the start of the
calendar quarter or shortly after they receive their next reporting package, along with the fee invoice for
that calendar quarter.

 Such inflation adjustments include indices that are designed to be proxies to inflation (i.e., Consumer Price Index), or fixed
annual percentage increases clearly detailed in Client FOAAs.

Form ADV Part 2A                                                                                     Disclosure Brochure: March 2026

All TwinFocus fees are calculated in accordance with a Client’s FOAA. In most instances, for the initial
partial quarterly period of the investment management services, fees are calculated on a pro rata/per
diem basis, based on the number of days in the first pertinent quarterly period until the next calendar
quarter. For fixed fee arrangements, the annual investment advisory fee is divided into four payments at
the beginning of each calendar quarter. For Clients not on fixed fee arrangements, but where fees are
based on the level of assets, the quarterly fee is based on the number of days in that calendar quarter
over the total number of days in a year, utilizing the fee level as valued as of the end of the immediately
preceding calendar quarter.

A FOAA between TwinFocus and a Client continues in effect until terminated by either party pursuant to
the terms of the FOAA. Unless otherwise agreed between a Client and TwinFocus, TwinFocus advisory
fees are prorated through the date of termination and any remaining balance is refunded to the Client.

TwinFocus’ asset-based fees vary and are based on the market value of the assets managed by TwinFocus
on the last day of the immediately preceding calendar quarter. Asset-based fees are generally derived in
accordance with the schedule below:

                                     Assets Under Management/
                                                                             Annual Fee (%)
                                           Advisory Tier ($)
                                            0 - $50 Million                      50 bps
                                          $50 - $100 Million                     40 bps
                                            $100 Million +                       25 bps

A Client’s Assets Under Management (AUM) (Aggregate Investment Portfolio or AUM (Other)) or other
similarly labeled asset metrics, are clearly defined and demarcated on each Client FOAA and consistent
with every periodic reporting package prepared for a Client thereafter.

With respect to the AUM for those Clients that own alternative investments 8 in their portfolios and
...

ITEM 7. TYPES OF CLIENTS
TwinFocus provides its services to individuals, pension and profit-sharing plans, trusts, estates, charitable
organizations and vehicles, family co-investment vehicles and family office structures, corporations, and
other business entities, and certain SPVs established to hold individual alternative investments on behalf
of Clients who also meet the requirements of accredited investors and qualified purchasers.

Further, as discussed in Item 4 above, TwinFocus also provides non-discretionary investment advice to an
FCA-registered adviser in the UK. Our clients reside, work, and are potentially subject to laws, rules, and
regulations of many different jurisdictions (i.e., both domestic in terms of states and local municipalities
and country domicile/residency jurisdictions).

Minimum Account Size
As a condition for starting and maintaining a relationship, TwinFocus generally imposes a minimum
advisory asset base / portfolio size of $100,000,000. TwinFocus, in its sole discretion, accepts Clients with
smaller asset bases/portfolios based upon certain criteria including anticipated future earning capacity,
anticipated future additional assets, dollar amount of assets to be managed, related accounts, account
composition, pre-existing relationship, strategic relationships, account retention, and pro bono activities.
In some instances, TwinFocus aggregates the portfolios of family members to meet the minimum asset
base / portfolio size.

Form ADV Part 2A                                                                 Disclosure Brochure: March 2026