Wincap Financial LLC

Item 5 – Fees and Compensation of the Disclosure Brochure for complete details on fees.

C. Fees
Wealth management fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the
wealth management agreement. Wealth management fees are based on the market value of assets under
management at the end of the prior calendar quarter. Wealth management fees range from 0.50% to 1.25%
annually based on several factors, including: the scope and complexity of the services to be provided; the level of
assets to be managed; and the overall relationship with the Advisor. Relationships with multiple objectives, specific
reporting requirements, portfolio restrictions and other complexities may be charged a higher fee.

The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the
end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed
by WinCap Financial will be independently valued by the Custodian. The Advisor will conduct periodic reviews of
the Custodian’s valuation to ensure accurate billing.

As noted above, the Wrap Fee Program includes normal securities trading costs incurred in connection with the
discretionary investment management services provided by WinCap. Securities transaction fees for Client-
directed trades may be charged back to the Client. Clients may incur certain fees or charges imposed by third
parties in connection with investments made on behalf of the Client’s account[s]. Under this Wrap Fee Program,
WinCap includes securities transactions costs as part of its overall wealth management fee.

In addition, all fees paid to WinCap for wealth management services or part of the Wrap Fee Program are separate
and distinct from the expenses charged by mutual funds and exchange-traded funds to their shareholders, if
applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will
generally be used to pay management fees for the funds, other fund expenses, account administration (e.g.,
custody, brokerage and account reporting), and a possible distribution fee. The Client may also incur other costs
assessed by the Custodian or other parties for account related activity fees, such as wire transfer fees, fees for
trades executed away from the Custodian and other fees. The Advisor does not control nor share in these fees. The
                                                   WinCap Financial LLC
                                             55 Union Street, Boston, MA 02108
                                     Phone: (617) 590-3250 | https://wincapfinancial.com

Client should review both the fees charged by the fund[s] and the fees charged by WinCap to fully understand the
total fees to be paid. Please see Item 5.C. – Other Fees and Expenses in the Disclosure Brochure (included with
this Wrap Fee Program Brochure).

D. Compensation
WinCap is the sponsor and portfolio manager of this Wrap Fee Program. WinCap receives wealth management
fees paid by Clients for participating in the Wrap Fee Program and pays the Custodian for the costs associated
with the normal trading activity in the Client’s account[s].

Item 5 – Account Requirements and Types of Clients
WinCap Financial offers wealth management services to individuals, high net worth individuals, trusts, and
estates. WinCap Financial generally does not impose a minimum relationship size.

Item 6 – Portfolio Manager Selection and Evaluation
Portfolio Manager Selection
WinCap serves as sponsor and as portfolio manager for the services under this Wrap Fee Program.

Related Persons
WinCap personnel serve as portfolio managers for this Wrap Fee Program.

Item 7 – Types of Clients

WinCap Financial offers wealth management services to individuals, high net worth individuals, trusts, and
estates. WinCap Financial generally does not impose a minimum relationship size.