A. Description of the Advisory Firm J2 Capital Management, Inc. was established in April 2009 and the principal owners are John Salomon, Jr. and John Benedict. B. Types of Advisory Services J2 Capital Management, Inc. (hereinafter “J2CM”) offers the following services to advisory clients: Investment Supervisory Services J2CM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. J2CM 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 (the Investment Policy Statement) to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring J2CM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. J2CM 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. Variable Annuity J2CM may perform tax free exchanges on existing variable annuity contracts that are outside of the surrender charge period for a new fee based variable annuity contract. J2CM will use only fee based variable annuity contracts because of their low fees, extensive investment options, and the ability to cancel without a back end charge. J2CM will also place new business into a fee based variable annuity for non-qualified money for clients seeking tax deferral. 401k Management J2CM provides asset management services for client 401k or other company retirement plans. The client will provide J2CM with the website, user name, and password in order to manage investments within the investment options provided. Accordingly, J2CM is not deemed to have custody in this arrangement.

Plans that allow the participants to change address or request a distribution via the website portal are not candidates for this service. Subadvisory Services J2CM offers several strategies to other advisors for use with their clients. These strategies are implemented through a brokerage or through the Nationwide variable annuity. 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. These services can be based on hourly fees and the final fee structure is documented in Exhibit II of the Financial Planning Agreement. Services Limited to Specific Types of Investments J2CM limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, REITs, insurance products and government securities. J2CM may use other securities as well to help diversify or hedge a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions J2CM offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets of the client. 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 J2CM from properly servicing the client account, or if the restrictions would require J2CM to deviate from its standard suite of services, J2CM reserves the right to end the relationship. D. Wrap Fee Programs J2CM does not participate in any wrap fee programs. E. Amounts Under Management J2CM has the following assets under management: Discretionary Amounts: Non- discretionary Amounts: Date Calculated: $ 161,401,813 .00 $0.00 June 30, 2023