Zanetti Financial LLC

Fees and Compensation (Item 5)
This section of the brochure describes how we are compensated for the services we offer.

Compensation Methodology and Rates
Assets Under Management
Client will pay Advisor a fee for its investment management services. The fee will be a
percentage of the market value of all assets (excluding cash) in the Account on the last trading
day of each calendar month. All fees will be payable in arrears for each calendar month on a
pro rata basis. The fee schedule is set forth in Schedule A. This fee may be amended from time
to time pursuant to an amendment to the contract to be mutually agreed to and signed by both
parties. In any partial calendar month, the management fee will be pro-rated based on the
number of calendar days that the Account was open during the month. Client understands that
all Account assets (except for cash that is not billed upon) not identified as “unsupervised” on
the account Custodian’s periodic published statements will be included in calculating the value
of the Account for purposes of computing Advisor’s fees and the same assets will also be subject

to additional advisory and other fees and expenses, as set forth in the prospectuses of those
funds, paid by the funds but ultimately borne by the investor.

Client authorizes the Custodian to deduct from this Account and pay to Advisor the
management fee for each calendar year month. The Custodian will send Client a quarterly
statement showing all amounts paid from the Account, including all management fees paid by
Custodian to Advisor. Fees are negotiable and similar services may be available at a lower rate.

Zanetti Financial charges its asset-based fee as follows:

Equities
        $0-$10,000 000       0.85% + NM Gross Receipts Tax
       $10,000,001 and above 0.50% + NM Gross Receipts Tax

Fixed Income
       $0-$10,000,000        0.20% + NM Gross Receipts Tax
       $10,000,001 and above 0.10% + NM Gross Receipts Tax

Cash 0%

Your specific annual fee arrangement will be described in the written Investment Advisory
Agreement entered into between Zanetti Financial and you. Investment advisory fees
charged by us are negotiable at our sole discretion. All clients do not pay the same fee. A
lower fee for a comparable service may be available from other sources. Again, the annual
fee for our services is billed monthly, in arrears, based on the value of the account at the
end of the month. If the management agreement does not span the entire monthly billing
period, the fee will be pro-rated based on the number of days the account is open during
the billing period. Your account custodian will send client statements, at least quarterly,
showing all disbursements for the account including the amount of the advisory fee, if
deducted directly from the account. We urge you to verify the accuracy of the fee
calculation as the account custodian will not determine whether the fee has been properly
calculated. See Brokerage Practices (Item 12) in this brochure for more information about
your account custodian(s).

Gross Receipts Tax (GRT) is imposed on firms doing business in the State of New Mexico. It is
permissible for a business to pass the GRT on to its clients and/or customers subject to certain
NM requirements. Zanetti Financial passes on the GRT to clients in addition to the management
fee and then pays that tax to the State of NM every month. For example, the standard annual
0.85% Zanetti Financial fee plus the current (2026) GRT of 7.625% would make the total

expense to the client of 0.926%. If clients would like an individual breakdown of the Zanetti
Financial fee vs. the NM GRT they can contact the office, and it will be provided. GRT expenses
are subject to change and Zanetti Financial will adjust GRT rates up or down in accordance with
State law.

You may terminate the Investment Advisory Agreement without fee or penalty by providing
written notice to Zanetti Financial within five (5) business days from the execution of the
agreement. Thereafter, either party may terminate the Investment Advisory Agreement by
providing written notice. Any unearned fees collected in advance of services being performed
will be returned to you on a pro rata basis.

Valuation of Publicly Traded Securities
Publicly traded securities in your account(s) managed by us are held at the custodian that
we recommend but is ultimately chosen by you. We use the securities valuation provided
by the independent qualified custodian for reporting and billing purposes. Publicly traded
securities are usually valued as of the end of business on the last trading day of the calendar
quarter. Other securities or investments in the Account will be valued in a manner
determined in good faith by Advisor to reflect fair market value. If clients have a dispute
regarding fair market value, the dispute will be taken to an arbitrator mutually acceptable
by both parties for resolution. Arbitration may not be enforceable in all jurisdictions.

How Clients Pay Advisory Fees
Fees are deducted directly from your account. You must provide your qualified account
custodian with written authorization to have fees deducted from the account and paid to
Zanetti Financial.

Other Types of Fees and Expenses
In addition to the investment advisory fees you pay to us, you will pay transaction fees
(commissions) to your custodian or broker-dealer for executing securities transactions and
charges for special services elected by you or Zanetti Financial. These fees may include:

   •   periodic distribution fees
   •   electronic fund and wire transfer fees
   •   certificate delivery fees
   •   reorganization fees
   •   account transfer fees (outbound)
   •   returned check fees

    •   international security transfer fees
    •   overnight mail and check fees
    •   Rule 144 transfer fees
    •   transfer agent fees

This list is not meant to be all inclusive. Any fee on a special service incurred by the client
...

Types of Clients (Item 7)
This section of the brochure describes who we generally provide our services to.

Zanetti Financial provides advisory services to a variety of types of clients including
individuals, trusts, individual’s pension plan accounts, and retirement plan trustees.

Methods of Analysis, Investment Strategies, and Risk of Loss