Description of the Firm NCM Capital Management, LLC is a New Jersey domiciled limited liability company formed in 2009. Our firm is not a subsidiary of nor does it control another financial services industry entity. In addition to our 2015 registration as an SEC investment advisor, our firm and its associates may notice-file (register), become licensed or meet certain exemptions to registration and/or licensing in other jurisdictions in which investment advisory business is conducted.. Nicholas S. Laverghetta, CFP® is the firm’s President and Chief Compliance Officer (supervisor). He is also Managing Member and maintains majority control in the firm. Description of Advisory Services NCM Capital Management, LLC provides fee-based financial planning and portfolio management services that may be broad-based or focused on a particular area of interest or need depending on the client’s circumstances or specific request An initial interview is conducted by a representative of our firm to discuss your current situation, goals and the scope of services that may be provided to you. During or prior to this meeting you will be provided with our Form ADV Part 2 firm brochure that includes a statement involving our privacy policy, as well as a brochure supplement about the representative who will be assisting you. Should the client wish to engage NCM Capital Management, LLC for its services, parties must enter into a written agreement, with further discussion and analysis conducted thereafter to ascertain financial need, goals, holdings, etc., as provided by the client. It is important that we are provided with an adequate level of information and supporting documentation throughout the term of the engagement including but not limited to: source of funds, income levels, and an account holder or attorney-in-fact’s authority to act on behalf of the account, among other information that may be necessary for our services. The information and/or financial statements provided to us need to be accurate. Our firm may, but is not obligated to, verify the information that you have provided to us which will then be used in the advisory process. It is essential that you inform our firm of significant issues that may call for an update to their plan. Events such as changes in employment or marital status, an unplanned windfall, etc., can have an impact on your circumstances and plans. Our firm needs to be aware of such events so that adjustments may be made as necessary. Financial Planning Services Financial planning services are provided on such subjects as cash flow analysis, retirement capital needs, education funding, estate planning, charitable giving, or other specific needs as indicated by the client. Our investment consultation component may involve educating the client on the types of investment vehicles available, investment analysis and strategies, asset selection, as well as assisting the client in establishing their own investment account at their selected broker/dealer or custodian. The client retains absolute discretion over all implementation decisions and is free to accept or reject any recommendation made by the firm. Engagements involving strictly financial planning services are concluded upon delivery of the requested service; however, the client is encouraged to engage the firm in the future. At no time will an engagement for these services span a calendar year period unless we are engaged for long-term services. Investment Management Services Clients may choose to engage the firm to implement the investment strategies it has recommended through its Investment Management Services platform. When appropriate, written investment guidelines are developed Page 5 of 19 reflecting the client's investment objectives, policy constraints, tolerance for risk, and reasonable restrictions involving investing in certain securities or types of securities. We may incorporate a blend of passive and active investment strategies and portfolio allocations generally designed for investors who seek long-term, tax efficient growth while attempting to control risk and volatility. The firm’s investment strategy and recommended vehicles are further described in Item 8 of this brochure. When NCM performs asset management services, NCM will do so on a discretionary basis. This means that while clients will communicate regularly with NCM, NCM will not seek specific approval of changes to client accounts. Clients can always make deposits or withdrawals in their accounts at any time. Clients should be aware that if NCM is managing the client’s assets, they may not be able to place restrictions on the types of investments in an account or portfolio. Because NCM takes discretion when managing accounts, clients engaging the Firm will be asked to execute a Limited Power of Attorney (granting NCM the discretionary authority

over the client accounts) as well as an Investment Management Agreement that outlines the responsibilities of both the client and NCM. We will also provide non-discretionary Investment Management Services to clients relative to variable life/annuity products that they may own through a specific issuer or accounts held by their individual employer sponsored retirement plans. The firm either directs or recommends the allocation of client assets among the various mutual fund subdivisions that comprise the variable life/annuity product or retirement plan. Wealth Management Services Our firm will provide clients with Wealth Management Services; combining Financial Planning with Investment Management Services provided on either a discretionary or non-discretionary basis in accordance with the client’s stated investment objectives (defined in Item 16). This service includes the development of a plan which takes into consideration business planning, investments, insurance, retirement, education, estate planning, and tax and cash flow needs of the client. Retirement Plan Rollovers Depending on a client’s given circumstances, NCM may recommend that a client rollover retirement plan assets to an Individual Retirement Account (IRA) managed by us. As a result, NCM may earn fees on those accounts. This presents a conflict of interest, as NCM has a financial incentive to recommend that a client roll over retirement assets into an IRA NCM will manage. This conflict is disclosed to clients verbally and in this brochure. Clients are also advised that they are under no obligation to implement the recommendation to roll over retirement plan assets. NCM attempts to mitigate this conflict by requiring that all investment recommendations have a sound basis for the recommendation, and by requiring advisors of NCM to acknowledge their fiduciary responsibility toward each client. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Page 6 of 19 Wrap Fee Programs Our firm does not sponsor or serve as a portfolio manager in an investment program involving wrapped (bundled) fees. Client Assets Under Management As of December 31, 2022, our firm managed approximately $361,247,869 dollars of client assets on a discretionary basis. Firm Services Our firm does not provide accounting, legal or insurance-related services. With your consent, we may work with other professional advisors, such as an estate planning attorney, to assist with the coordination and implementation of accepted strategies. You should be aware that these other advisors will charge you separately for their services and these fees will be in addition to our own advisory fees. Our firm will use its best judgment and good faith effort in rendering its services. We cannot warrant or guarantee the achievement of a planning goal or any particular level of account performance or that your account will be profitable over time. Past performance is not necessarily indicative of future results. Except as may otherwise be provided by law, our firm will not be liable to the client, heirs, or assignees for any loss an account may suffer by reason of an investment decision made or other action taken or omitted in good faith by our firm with that degree of care, skill, prudence and diligence under the circumstances that a prudent person acting in a fiduciary capacity would use; any loss arising from our adherence to your direction or that of your legal agent; any act or failure to act by a service provider maintaining an account. Federal and state securities laws impose liabilities under certain circumstances on persons who act in good faith and, therefore, nothing contained in this document or our client engagement agreement shall constitute a waiver of any rights that a client may have under federal and state securities laws.