Bay Hills Capital Management, LLC

• A percentage of assets under your management
• Performance-based fees

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

The brochure lists different fees for different services or strategies; see the brochure for them.

Account minimum: $1,000,000 (the brochure says it may be waived or negotiated)

As stated in the firm's Form ADV Part 2A brochure dated March 31, 2026. Fees can differ by service and may be negotiable; the brochure is the complete statement. Read the brochure on the SEC's IAPD site

$569,785,000 as of October 2026, filing dated March 31, 2026.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

• Portfolio management for pooled investment vehicles (other than investment companies)
• Selection of other advisers (including private fund managers)
• Other

Registration

SEC-registered investment adviser. Status as filed: Approved.

Registered since

2012 (14 years)

Employees

Total: 7. Performing investment advisory functions: 5.

Wrap fee program participation

No.

States registered or notice-filed

1 state or jurisdiction

CA

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

1 Reports 1 disclosure item on Form ADV Item 11. View on IAPD.

Questions answered yes on this filing

Civil court matters Item 11.H

• 11.H(1)(b) Has a domestic or foreign court ever found that the firm or an advisory affiliate was involved in a violation of investment-related statutes or regulations?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. What happened, and who was involved, is on the Disclosure Reporting Pages of the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $617,073,750 in the October 2021 data and $569,785,000 in the October 2026 data, down 8%.

Total employees: 8 in October 2021 and 7 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

1. April 2026
   • Its Item 11 disclosure answers changed (now yes: 11.H(1)(b); now no: 11.H(2)).
   • Regulatory assets under management went from $873,685,000 to $569,785,000 (-35%).
   • Updated its list of owners and control persons (Schedule A).

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.