Vanguard Personalized Indexing Management

Item 5| Fees and Compensation

     A. Fee Schedule
     Please note that lower fees for comparable services may be available from other sources. We encourage all
     Clients to evaluate our services and fees relative to other investment advisory service providers.

     Sub-Advisory Fees
     For sub-advisory arrangements, fees are negotiated with the primary RIA or wealth manager of the end
     Client, not directly with the end Client. For sub-advised separately managed strategies, VPIM charges an
     annual management fee based on a percentage of the end Client’s account value. Additionally, end Client’s
     custodians may charge fees in addition to the investment advisory fees charged by VPIM.

 Adviser Aggregate Assets Under Management                          Annual Fee Rates

 $250,000 to $50,000,000*                                                 0.20%

 $50,000,001 to $100,000,000                                              0.18%

 $100,000,001 to $500,000,000                                             0.15%

 $500,000,001 and over                                                   Custom

  Individual Account Assets Under Management                        Annual Fee Rates

 $10,000,000 to $50,000,000                                               0.15%

 $50,000,001 to $100,000,000                                              0.13%

 $100,000,001 and over                                                   Custom

Accounts will be assessed the lower available rate between the two above tables, where possible and as
applicable. To provide a hypothetical example, if an RIA or wealth manager maintains $15,000,000 in assets
under management with VPI across their book of business, of which $10,000,000 are attributable to a single
client account, then that account would be assessed an annual fee rate of 0.15%, and the balance of assets
would be assessed an annual fee rate of 0.20%.

VPIM’s preferred minimum account size is $250,000. Clients introduced to VPIM through a Turnkey Asset
Management Program, have a higher minimum account size of $1,000,000. We reserve the right to provide
services at smaller account sizes at our discretion.

For an end Client account, other than accounts held with a TAMP/Wrap Fee Program, that select certain
investment universes represented by certain index providers, additional index licensing fees ranging from
.010% to .0275% will be charged.

VPIM may negotiate lower fees depending on the nature of the strategy, account size, and overall
relationship. VPIM reserves the right to negotiate fees that may be more or less advantageous than those
charged to other Clients for similar services. VPIM’s fees may be billed quarterly or monthly in advance or
arrears, as outlined in the Sub-Advisory Agreement entered into with the primary Registered Investment
Adviser.

Direct Client Fees
For direct Clients of VPIM, we charge fees based on the market value of the assets managed. Furthermore,
the end Client’s broker-dealer and/or custodian may assess additional fees for certain services in addition
to the investment advisory fees charged by VPIM. We encourage investors to review their respective

broker-dealer’s Form CRS and associated schedule of charges for more information. The VPIM fee schedule
for Direct Clients is tiered as follows:

    ▪    0.27% on portfolios with total assets between $10 million and $15 million;
    ▪    0.22% on portfolios with total assets between $15 million and $25 million;
    ▪    0.17% on portfolios with total assets between $25 million and $50 million;
    ▪    0.12% on portfolios with total assets between $50 million and $100 million
    ▪    Custom fee rate on portfolio assets exceeding $100 million;

When an account reaches a break point, the full value of the account is repriced to the lower price, not just
the amount above the break point.

Certain other factors including custom data requirements, asset location services, and multi-account tax
coordination may incur additional fees that will be enumerated in the investment management contract.
VPIM reserves the right to provide periodic fee waivers where it deems appropriate. VPIM may negotiate
lower fees depending on the nature of the strategy, account size, and overall relationship. VPIM reserves
the right to negotiate fees that may be more or less advantageous than those charged to other Clients for
similar services.

There is an account minimum of $10,000,000, which may be waived by VPIM in its discretion.

Wrap Fees
The fees received by VPIM from each Wrap Sponsor are generally equal to either: (a) a percentage of the
total assets in the Wrap Sponsor’s Wrap Program accounts for which VPIM provides investment
management services; or (b) a percentage of the Wrap Fees actually collected by the Wrap Sponsor from
Wrap Clients to whom VPIM provides investment management services.

VPIM is not informed of the specific fee arrangement negotiated between each Wrap Client and the Wrap
Sponsor. Wrap Sponsors charge a minimum annual Wrap Fee to each of their Wrap Clients. Complete
information on the services provided and fees charged under a Wrap Program can be found in each Wrap
Sponsor’s Wrap Fee Program Brochure. Wrap Clients should carefully evaluate all information in the
applicable brochure to determine whether or not the Wrap Fee paid for the services provided exceeds the
aggregate cost of such services if they were to be provided separately.

B. Payment of Fees
Payment of Portfolio Management Fees
All payment terms, including the frequency and method of fee withdrawal, are detailed and mutually agreed
upon in either the Investment Advisory Contract or Sub-Advisory Agreement, as appropriate for the specific
client relationship.

VPIM will periodically withdraw its fees based on the following methodology: fees will be calculated and
due quarterly, in arrears, based on the value of the account(s) as reported by the Custodian as of the last
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Item 7 | Types of Clients
     VPIM serves a variety of Client types, including individuals and families, family offices, small endowments
     and foundations, other Registered Investment Advisers and Registered Investment Companies. We service
     these Client types predominantly on behalf of other RIAs or wealth managers in a sub-advisory capacity. We
     also service individual Clients directly. For each Client type, we apply a standard methodology, but
     dependent on the unique needs, characteristics, and mission of each Client, we tailor custom investment
     choices that are specific to each Client.

     Certain officers, directors, and substantial shareholders, including any employees subject to Rule 144 of the
     Securities Act of 1933, as amended, or Section 16 of the Securities Exchange Act of 1934, as amended, are
     not eligible for VPIM advisory services. Clients are generally required to maintain permanent residence in
     one of the of 50 states, the District of Columbia, or the U.S. Virgin Islands. Clients that are temporarily
     abroad, such as those in the military or on government duty, may be eligible under consideration of
     additional information.