Capstone is owned 100% by JMF Wealth Management, LLC. Capstone has been providing advisory services since 1999. As of December 31, 2023, Capstone managed $333,317,515 on a discretionary basis and $3,056,449 on a nondiscretionary basis. In addition, we advised on $75,694,780 of self- directed retirement account assets. InvestmentManagementServices: Capstone manages investment portfolios for individuals (including high net worth individuals), qualified retirement plans, trusts, charitable organizations and foundations as well as corporations and small businesses. Capstone works with clients to determine the client's specific investment objectives and these may be set forth in a written Investment Policy Statement that describes an asset allocation model that conforms to a client's risk tolerance level. Investment and portfolio allocation software may be used to evaluate alternative portfolio designs. Capstone evaluates clients' existing investments with respect to their investment policy statements and works with new clients to develop a plan to transition from client's existing portfolio to the portfolio recommended by Capstone. Capstone then continuously monitors client's portfolio holdings and overall asset allocation strategies and holds regular review meetings with clients regarding their account, as necessary. Capstone will typically create a portfolio of passively and/or evidence-based mutual funds and exchange traded funds, and, where appropriate, can use model portfolios if the models match a client's investment policy. Capstone will allocate a client's assets among various investments taking into consideration the overall management style selected by the client. Mutual funds or exchange traded funds (ETFs) that follow a passive and/or evidence- based investment philosophy generally have low holdings turnover. Consequently, the fund expenses are generally lower than fees and expenses charged by other types of funds. Client portfolios can also include some individual equity securities where disposition of these securities would present an overriding tax implication, or the client specifically requests they be retained for a personal reason. Capstone manages portfolios on a discretionary and, in very limited circumstances, on a non-discretionary basis. A client may impose any reasonable restrictions on Capstone’s discretionary authority, including restrictions on the types of securities in which Capstone may invest client’s assets and on specific securities, which the client may believe to be appropriate. Capstone may also recommend fixed income portfolios to investment management clients, which consist of managed accounts of individual bonds. Capstone will request discretionary authority from investment management clients to manage fixed income portfolios, including the discretion to retain a third-party fixed income manager. On an ongoing basis, Capstone will answer clients’ inquiries regarding their accounts and review periodically with clients the performance of their accounts. Capstone will periodically, and at least annually, review clients’ investment policy, risk profile and discuss the re-balancing of each client's accounts to the extent appropriate. Capstone will provide to investment manager any updated client financial information or account restrictions necessary for investment manager to provide sub-advisory services. In addition to managing the client’s investment portfolio, Capstone may consult with clients on various financial areas including income and estate tax planning, business sale structures, college financial planning, retirement planning, insurance analysis, personal cash flow analysis, establishment and design of retirement plans and trust designs, among other things. Selection of Independent Managers Capstone may retain third-party investment advisers to manage a portion of the clients’ assets. Pursuant to the terms of the investment advisory agreement, Capstone will have the discretion to hire and terminate these third-party advisers. Pursuant to its discretionary authority, Capstone will retain a fixed income securities manager. The fixed income securities manager will be provided with the discretionary authority to invest client assets in fixed income securities. The manager will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost basis information). The manager will obtain Capstone’s consent prior to the sale of any client securities. Additionally, Capstone may allocate a portion of a portfolio to an independent third-party

investment advisor (“Independent Manager”) for separate account management based upon individual client circumstances and objectives, including, but not limited to, client account size and tax circumstances. Pursuant to the terms of the investment advisory agreement, Capstone shall have the discretion to appoint and terminate these third-party advisers. The specific terms and conditions under which a client engages an Independent Manager may also be set forth in a separate written agreement with the designated Independent Manager. However, not all Independent Managers require a separate advisory agreement with the designated Independent Manager. Disclosure of the use of an Independent Manager and their additional fees will be provided to clients. Independent Managers utilized by Capstone include BSP, Dimensional Funds Advisors, Parametric and Aperio. Financial Planning Services Capstone may utilize the services of Delegated Planning, LLC, an independent, registered investment advisor that provides financial planning support services to other registered investment advisors. The services provided by Delegated Planning, LLC are tailored to Capstone’s specific requests and generally include the following: ● Developing new or updating existing financial plans for clients of Capstone, encompassing specific planning areas. These areas may include: o CashFlowAnalysis: Create a statement of cash flow to illustrate inflows and outflows of cash. Determine if calculations match expectations of financial projections. o BalanceSheetAnalysis: Create a net worth statement. o RetirementAnalysis: Projecting if clients will have the resources to achieve their stated retirement goals. If not, provide optional strategies and choices to improve the probability of success. o SurvivorshipNeedsAnalysis: Determine if current life insurance coverage is appropriate given clients’ resources and stated survivorship goals. If not, provide optional strategies and choices to improve the probability of success. o DisabilityNeedsAnalysis: Determine if current disability insurance coverage is appropriate given clients’ resources and stated financial goals. If not, provide optional strategies and choices to improve the probability of success. o Long‐TermCareNeedsAnalysis: Run a projection to stress test the impact of long-term care costs on retirement. Provide optional strategies and choices to improve the probability of success. o EducationFundingAnalysis: Determine if clients will have the resources to achieve their stated education goals. If not, provide optional strategies and choices to improve the probability of success. ● Researching issues relating to any of the items listed above. All financial plans and deliverables are reviewed and approved by Capstone, who then presents the final plan to our client. Although Delegated Planning may have contact with Capstone’s clients, communications generally relate to data gathering and communications at the request of Capstone. No advice is provided directly to Capstone’s clients by Delegated Planning without pre-approval from the Financial Advisory Firm. EmployeeBenefitRetirementPlanServices: Capstone also provides advisory services to participant-directed employee retirement benefit plans. Capstone will analyze the plan's current investment platform, and assist the plan in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. Capstone will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. Capstone will recommend changes in the plan's investment vehicles as may be appropriate from time to time. Capstone generally will review the plan's investment vehicles and investment policy as necessary. For certain retirement plans, Capstone also works in coordination and support with Buckingham Strategic Partners, LLC. Retirement plan clients will engage both Capstone and Buckingham Strategic Partners, LLC. Buckingham Strategic Partners, LLC will provide to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintain the plans’ investments according to the goals and investment objectives of the plan. Capstone will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan.