Royale Asset Management LLC (“RAM”) has been in business since November 2015. William Masucci is the firm’s only principal owner. Prior to forming RAM, Mr. Masucci was the CEO/CFO of a large family office in Upstate New York. RAM provides services to a select group of clients, who are most typically high net worth individuals and family offices, and may also provide referrals and non-investment related consulting services. RAM’s primary objective is to handle clients of high net worth, typically with multiple outside money managers, and act as the intermediary between the owner of the wealth and the other managers. Each client receives financial management services from RAM that are specifically tailored to that individual or family. These services are not typical financial planning services whereby goals and objectives are obtained and a plan made to achieve them. Typical RAM clients are instead more concerned with managing the various relationships, including money managers, banks, attorneys, accountants and other professionals needed to ensure their wealth is maintained and ultimately transferred to the intended parties. We are often referred to as a client’s “Gatekeeper”, as our role is overseeing a client’s overall investment strategy and acting as the main contact point and advocate for each client. This allows clients to focus on living their lives, and not worryabout other professionals trying to sell them products. We refer to this as “keeping the wolves at bay”. The process begins with a review of the totality of a client’s financial circumstances, which may include current estate plans, trusts, other assets, and investments. At times, the organizational structure of these circumstances can be very complex, with various trusts and family partnerships created to hold and manage the family’s wealth. RAM’s services include monitoring asset allocation, manager selection, and due diligence on money managers.. We are there to act as an advisor on all key decisions, whether it be home purchase or a major investment. Our goal is to streamline these organizations and hopefully therefore reduce costs by reviewing available documents and accounts and then working with all of the client’s other professionals in an effort to provide seamless management of each client’s financial life. Our clients find all of the information they need in one place, organized in a manner that can be easily understood. Individuals often come to RAM with an assortment of existing managers, and in many cases, these managers are in RAM’s opinion appropriate choices for the individual’s assets. Where RAM attempts to add value is through the management of these managers: pressing each manager for specific concessions for the RAM client’s benefit, challenging the manager’s thought processes, and finding newer and emerging managers the larger firms may have ignored. If RAM believes that a manager, or managers, are not performing their duties, or feels the client’s needs can be met better elsewhere, RAM will seek to make a change of managers. Depending on the specific arrangement with each client, RAM could have the authority to hire and fire managers with discretion, meaning without first consulting the client, or on a non-discretionary basis, where

we would consult with the client prior to making a manage change. As an adviser that is not affiliated with a bank or large institution, we believe we have the ability to see the bigger picture in terms of the client’s overall circumstances and portfolio. In cases where we manage assets directly and not through third party managers, we can perform that service on either a discretionary or non-discretionary basis. You may at any time place restrictions on the types of investments we may use on your behalf, or on the allocations to each security type. You will also receive statements at least quarterly from your account custodian. Clients engaging us on a discretionary basis will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) as well as an Investment Management Agreement that outlines the responsibilities of both the client and RAM. For clients who engage RAM on a non-discretionary basis, while we will continue an ongoing relationship with each client, being involved in various stages of their lives and decisions to be made, we will seek specific approval of changes to client accounts before any changes are made. Clients can always make deposits or withdrawals in their accounts at any time. Clients will be responsible for executing an Investment Management Agreement that outlines the responsibilities of both the client and RAM. If you request, RAM may recommend the services of other professionals for implementation purposes. You are under no obligation to engage the services of any such recommended professional. You retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendation from RAM. If you engage any professional recommended by RAM, and a dispute arises thereafter relative to such engagement, you agree to seek recourse exclusively from and against the engaged professional. Consulting Services RAM may provide consulting services to Institutional Clients (Advisers and Broker-Dealers) as well as individuals that work at non-affiliated companies (including investment and non-investment related matters, including estate planning, retirement planning, tax planning, marketing consulting for private companies, etc.). Consulting services may also be offered to individuals at other investment advisors. Prior to engaging RAM to provide planning or consulting services, Institutional Clients and individuals are generally required to enter into a written agreement with RAM setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the Institutional Client and individuals prior to RAM commencing services. Assets Under Management As of December 31, 2023, RAM had $__________________________________in assets under management which were managed across 39 total accounts. Of that total, $________________ were managed on a discretionary basis. As of the same date, RAM has an additional $____________________of assets under advisement. Assets under advisement mean assets of our clients for which we provide recommendations but do not have continuous and regular supervision of those assets.