VRM Penzini Capital L.L.C.

• A percentage of assets under your management
• Fixed fees (other than subscription fees)
• 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

See the firm's brochure (dated March 24, 2026) for its fees and any account minimum, on the SEC's IAPD site.

$269,217,587 as of October 2026, filing dated March 24, 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)

Registration

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

Registered since

2026 (0 years)

Employees

Total: 4. Performing investment advisory functions: 3.

Wrap fee program participation

No.

Other offices (Schedule D, Section 1.F)

1 other office, as of the April 2026 filing

Coral Gable, FL

States registered or notice-filed

1 state or jurisdiction

PR

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

None Reports no disclosure items on Form ADV Item 11. View on IAPD.

Item 11 asks about criminal, regulatory, and civil events involving the firm and its advisory personnel. The detail of each yes answer is on the IAPD record. Reading a firm's disclosures

1. April 2026
   • Updated its list of owners and control persons (Schedule A).
2. December 2025
   • Began filing reports as an exempt reporting adviser.

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