Anchor Bay Capital, Inc. ("ABC" or “the Adviser”) was incorporated in 2006 and is a successor to Anchor Bay Capital Management, LLC (formed in 2001), itself a successor to Spiering Investment Management, LLC, formed in 1992. The firm's principal owners are James Allen, Scott Spiering, Matt Large, and Tanner Wrisley. Investment Management Services ABC offers Investment Management Services ("IMS"). ABC implements its Investment Management Services by buying and selling stocks, bonds, mutual funds, Exchange- Traded Funds ("ETFs") and other investment securities in client accounts maintained at various custodians. ABC constructs the portfolios by combining stocks, bonds and other securities that pass its selection criteria. The percent allocated to fixed income (increasing for lower risk portfolios) and equities (increasing for more aggressive portfolios). To determine which securities meet its selection criteria, ABC conducts independent research (due diligence) to determine which stocks, bonds and other investment securities meet its criteria and in ABC's opinion offer the best risk/reward in isolation and as part of a diversified investment portfolio. ABCs due diligence process and investment selection criteria may vary depending on market conditions. Clients may impose restrictions on the account regarding securities that may not be bought or sold. ABC will flag those assets and will maintain the asset in the account until instructed otherwise by the client. ABC presents clients with model asset allocations based on their objectives, risk profile and financial status among other facts. The term model doesn’t apply to portfolio holdings only the allocations. ABC offers the following model allocations: Balanced ETF – Generally a 60% allocation to equities and 40% allocation to fixed income ETFs and bonds are maintained. Growth ETF – Generally an 80% allocation to equities and 20% allocation to fixed income ETFs and bonds are maintained. Conservative Individual Stocks – Generally a 45% allocation to individual stocks and 55% allocation to fixed income ETFs and bonds are maintained. Moderate Growth Individual Stocks – Generally a 64% allocation to individual stocks and 36% allocation to fixed income ETFs and bonds are maintained. Growth Individual Stocks – Generally a 79% allocation to individual stocks and 21% allocation to fixed income ETFs and bonds are maintained. Strategic Income – Generally a 53% allocation to dividend and income producing stocks and 47% allocation to fixed income ETFs and bonds are maintained. Investment Advisory Services are custom tailored specifically to the client. For Investment Management Services clients, the client's assets are invested in a portfolio consistent with the client's risk profile, which ABC determines based on the results of the Financial Plan or the Investment Adviser Representative's consultation with the client. Retirement Plans Adviser is being retained as an “investment manager” to the Client and the ERISA plan named above (Plan) as defined in the Employee Retirement Income Security Act of 1974 (as amended) (ERISA), Section 3(38). Adviser will make available to the Client a plan profile that will be utilized to develop a customized investment policy statement (IPS). The IPS will set forth the number of general investment options and asset class categories to be offered to Plan participants with a goal of providing a menu of investments that will allow for the creation of well-diversified portfolios designed to provide for long-term appreciation and capital preservation through a mix of equity and fixed income exposures. The Adviser will provide investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s IPS, investment policies and objectives and will make initial selections of Plan assets in consultation with the Client. Adviser will assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and will make recommendations to maintain or remove and replace investment options. Adviser will meet with Client on a periodic basis to discuss the reports and the investment recommendations. Adviser will retain final decision-making authority with respect to removing and/or replacing investments and will be responsible for communicating instructions to any third-party, including the plan’s record keeper, custodian and/or third- party administrator. If Plan portfolios designed by the Adviser contain assets that represent only a portion of the Plan's assets, the Client understands that the Adviser will have no responsibility for the diversification of assets outside of the portfolios for which the Adviser is responsible under the terms

of the Agreement. The Adviser will have no duty, responsibility or liability for managing assets that are not included in these portfolios. Investment Consulting Retirement Plans The Adviser will provide investment services pursuant to the Employee Retirement Income Security Act of 1974 (as amended) (ERISA), Section 3(21)(A)(ii) and will neither act as an investment manager nor have any discretionary authority over any assets that are invested in the Plan. The Adviser will assist the Client in developing a plan profile that will be utilized to develop a customized investment policy statement (IPS). The IPS will set forth the number of general investment options and asset class categories to be offered to Plan participants with a goal of providing a menu of investments that will allow for the creation of well- diversified portfolios designed to provide for long-term appreciation and capital preservation through a mix of equity and fixed income exposures. Client will have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS. The Adviser will provide investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s IPS, investment policies and objectives. Client will have the final decision-making authority regarding the selection, retention, removal and addition of investment options. Adviser will assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and will make recommendations to maintain or remove and replace investment options. Adviser will meet with Client on a periodic basis to discuss the reports and the investment recommendations. The Client represents that the Adviser has been furnished with true and complete copies of all documents establishing and governing the plans and evidencing the Client's authority to retain the Adviser. Client retains, and will exercise, final decision-making authority and responsibility for the implementation of any recommendations or advice rendered to Client by Adviser. The Adviser may conduct participant group meetings and educate participants about plan investment alternatives. Retirement Plan Participants ABC will enter into a relationship with a client that wants ABC to provide investment planning on an ongoing basis; this may include but is not limited to investment selection, and investment monitoring services for assets held in an employer sponsored retirement plan. Services will be consistent with the investment objectives, risk profile and financial status of each client. Wrap Fee Programs At the present time ABC does not provide portfolio management services to wrap fee programs. Assets Under Management As of December 31, 2023, ABC had approximately $205,949,000 in discretionary assets under management and $2,567,000 in non-discretionary assets under management. Financial Planning Services Financial Planning Services include the preparation and presentation of a Financial Plan that projects future cash flow based on assumptions about growth of assets, which the client can use for retirement, budgetary and estate planning. A financial plan also helps the client and ABC to determine the desired return on investments, a crucial element in the selection of an appropriate investment portfolio. A plan includes investment recommendations that the client may choose to adopt. If the client chooses to retain ABC to implement the investment recommendations, the client becomes an Investment Management Services client. If the client decides to hire a different investment manager, or to manage the investments on his or her own without the involvement of ABC, the client is billed on a fee for service basis for the Financial Plan and Consultation. Financial Planning Conflicts of Interest There is a potential conflict of interest because there is an incentive for the Adviser offering financial planning services to recommend products or services for which the Adviser or an associated person may receive compensation. However, financial planning clients are under no obligation to act upon any recommendations of the Adviser or to execute any transactions through the Adviser or an associated person if they decide to follow the recommendations. Conflicts of Interest (California) All material conflicts of interest under CCR Section 260.238 are disclosed regarding the investment adviser, its representatives or any of its employees, which could be reasonably expected to impair the rendering of unbiased and objective advice, are disclosed within this brochure.