A. Description of the Advisory Firm Front Row Advisors LLC d/b/a GenCap Portfolio Management (hereinafter “FRA LLC”) is a Limited Liability Company organized in the State of California. The firm was formed in July 2015, and the principal owner is GenCap Partners LLC. B. Types of Advisory Services Portfolio Management Services FRA LLC offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. FRA LLC creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring FRA LLC evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. FRA LLC will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. FRA LLC seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of FRA LLC’s economic, investment or other financial interests. To meet its fiduciary obligations, FRA LLC attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, FRA LLC’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is FRA LLC’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Subadviser Services FRA LLC may also act as a subadviser to advisers unaffiliated

with FRA LLC. These third- party advisers would outsource portfolio management services to FRA LLC. This relationship will be memorialized in each contact between FRA LLC and the third-party adviser. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Services Limited to Specific Types of Investments FRA LLC generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs, treasury inflation protected/inflation linked bonds, commodities and non-U.S. securities, although FRA LLC primarily recommends equities to a majority of its clients. FRA LLC may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions FRA LLC will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by FRA LLC on behalf of the client. FRA LLC may use “model portfolios” together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent FRA LLC from properly servicing the client account, or if the restrictions would require FRA LLC to deviate from its standard suite of services, FRA LLC reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. FRA LLC does not participate in any wrap fee programs. E. Assets Under Management FRA LLC has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $276,667,677.00 $32,553,614.00 December 2023