Firm Description O’Keefe Stevens Advisory, Inc., hereinafter referred to as OSA or the Firm, is a Registered Investment Advisory firm, registered with the Securities and Exchange Commission (SEC), and manages portfolios in securities for individuals and trusts. The Firm’s initial registration was accepted by the SEC in February of 2017. OSA is a privately held corporation whose principal owners and Investment Advisor Representatives are Peter S. O’Keefe and Justin D. Stevens. In conjunction with its registration with the SEC, the Firm has also notice filed to conduct advisory business in the States of New York, Florida, California, Pennsylvania, Georgia and Texas, as required by those respective states’ registration requirements. OSA provides personalized confidential financial planning, asset management and related consulting services to individuals, high net worth individuals, pension and profit sharing plans, trusts, charitable organizations and small businesses. Recommendations to clients are made based on consultation with the client and analysis of each client’s specific financial needs and may include following services: Determination of financial objectives Identification of financial problems Cash flow management Tax planning Insurance review Investment management Education funding Retirement planning Estate planning Within the context of providing these services, clients may place restrictions on the types of securities to be held within their portfolios. OSA, at this time, does not offer its clients wrap fee programs. These programs charge a fee for an investment program that bundles together a suite of services, such as brokerage, advisory, research and management. OSA views its role as pursuing for its clients a superior return on investments consistent with clients’ desires for preservation of capital and the achievement of the individual goals of the clients. We seek to accomplish this by investing in securities with greater potential with a focus on safety of principal coupled with buying securities that sell at a discount to underlying asset values. At this time, OSA is a fee-only advisory firm and does not provide commission-based investment products to its clients. While some Investment Advisor Representatives (IARs) are licensed to offer non-variable insurance-related products to advisory clients of the Firm, they receive no commission income which might otherwise be derived from those activities should a client elect to accept their recommended products. Likewise, OSA does not receive commission income from such transactions either. Investment advisory services are provided to clients on a discretionary basis only. OSA does not act as a custodian of client assets, opting instead to utilize as its custodial Platform Charles Schwab & Co., Inc. (Charles Schwab). Charles Schwab is an unaffiliated SEC-registered broker/dealer and member of FINRA/SIPC. OSA may, to better serve specific client needs, elect to use the services of other or additional custodians as well. OSA’s governing policy is that client’s interests are always placed first and foremost. It serves clients with portfolios of several thousand to several million dollars. Clients with portfolios in this range have, in the past, had limited options. They could manage their portfolios themselves, buy mutual funds, rely on large institutional mangers or use bank trust departments. None of these options provide adequate attention and individualized professional management. While clients always maintain control of their assets, they authorize OSA to transact trades on their behalf, without prior consultation, by the discretion authorization contained in the discretionary advisory agreement executed with the Firm. A written evaluation of each client's initial situation may be provided to the client, at the discretion of their IAR. Account reviews with clients are offered and conducted at least annually by the IAR and periodic interim reviews may also be conducted with clients to provide reminders of the specific courses of action that need to be taken. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) may be engaged directly by the client or by OSA on behalf of a client, on an as-needed basis and with client approval. Conflicts of interest which might arise based on positions or actions of OSA will be immediately disclosed to the client in the unlikely event they should occur. An initial meeting with a prospective client, which may be by telephone, is free of charge and is considered an exploratory discovery interview to determine if/or the extent to which the financial planning or investment management services offered by OSA may be beneficial and appropriate to the client. In the event, as a result, the Firm is engaged by the client to provide those services, an advisory agreement is executed between the parties which defines the nature and cost of the services contracted. The Firm’s asset management philosophy is based on a simple proven premise that greater and more consistent gains are likely by investing in a diverse portfolio of securities that are priced below their intrinsic value. This philosophy stresses minimizing the risk of permanent loss of capital. Stock and bond investments are evaluated for quality and liquidity. Each client’s IAR places emphasis on having an intimate familiarity with the various holdings within their specific investment portfolio. In selecting the securities to be added to a client’s portfolio, a proprietary checklist is utilized to evaluate potential investment selections, which encompasses a holistic view of the underlying company. Every investment is appraised for opportunities and risks, and a thesis is developed on how each security might succeed. The effectiveness of this process is in a perpetual state of improvement, as each investment presents a learning opportunity. Investments are typically made for the long-term in corporations with unusual opportunities and are not limited to any one style such as large capitalization, small capitalization, international or fixed income. Research is focused on quantitative elements and technical analysis is rarely employed. While principally an equity investor, due to the usually higher returns, OSA can adjust asset allocations between stock, bonds, and money market funds, when appropriate. Individual portfolios are invested in a mix of securities such as stocks, corporate bonds, government bonds and money market funds. The mix among the securities alternatives is determined by their relative attractiveness at a specific time. The national and international economic climates and market conditions are keys in the mix decision. Portfolios remain in the client’s name, with Charles Schwab acting as custodian. While OSA is granted discretionary trading authority by its clients, it neither accepts authority to withdraw cash or securities from client accounts nor assumes custody of client assets in any other form beyond its ability to directly deduct advisory fees from client accounts. Clients receive quarterly status reports that set forth the results for the previous quarter and for the year-to-date. These reports are augmented by personal meetings at least annually or more frequently if desired by the client or their IAR. Principal Owners As previously stated, the principal owners of OSA are Peter S. O’Keefe and Justin D. Stevens, with each holding a 50% ownership interest in the Firm. Types of Advisory Services OSA provides both investment supervisory services, also known as asset management services, as well as financial planning and consultative services to its clients. Asset management services may entail the active or passive management of investment accounts, furnishing of investment advice through consultations with clients, issuing periodic newsletters or special reports to its clients about securities and market conditions or trends and evaluating securities held by clients to foster an understanding of their assets relative to their stated goals and objectives. Financial planning services are provided to clients to assist them in pursuing both short- and long-range financial goals. This is accomplished through a process of collecting client information about the client’s current financial condition, clarification of their goals, identification of their past efforts and current abilities in pursuit of their goals and ongoing progress reviews relative to any actions taken. On more than an occasional basis, OSA furnishes consulting services to clients on matters not involving securities, such as taxation, trust management and estate planning, but are directly related to the ongoing management of client assets. However, the Firm does not act in any capacity as a tax or legal advisor to its clients. The Firm is compensated for its advisory services to clients through asset management fees, fixed fees or hourly fees, which are determined by the types of services elected by the clients. Clients grant the Firm discretionary powers which permit the execution of transactions for clients without consulting with or obtaining consent from them in advance of the transactions. As stated above, this authorization is granted within the advisory agreements initially signed by the clients. As of December 31, 2023, OSA had $323,144,360 in assets under management for 293 clients (households) held in 755 advisory client accounts. As stated above, at this time all assets are managed on a discretionary basis. Tailored Relationships The goals and objectives

for each client are documented in our client relationship management system. Investment strategies are then created that reflect the stated goals and objectives of each client. Clients retain the option of imposing restrictions on investing in certain securities or types of securities. Types of Agreements Prior to engaging OSA’s services, clients are required to sign an agreement which defines the services that will be provided by the Firm. The following agreements define the typical client relationships between OSA and its clients. Agreements may not be assigned or transferred to parties other than the original clients entering into the agreements. Since OSA does not maintain custody of client assets, however, separate agreements may also need to be executed between custodial firms and the client, in addition to the agreements of the Firm described below. Since neither OSA nor its advisors act as attorneys, their recommendations should not be interpreted as legal advice. Financial Planning and Consulting Service Agreement Planning or consulting service clients are required to sign a Financial Planning and Consulting Service Agreement with the Firm. This agreement outlines the nature and level of advisory services to be provided, without requiring the direct management of the client’s assets. If they are already clients of the firm and have an investment management agreement signed, a Financial Planning Agreement may not be necessary. Existing clients are not charged a fee for financial planning services at this time. This is included in their investment management fee. For financial planning clients, information regarding a client’s personal and financial situation and objectives is collected by the advisor through a confidential interview process. This data is analyzed and a written financial plan, with specific recommendations, is presented to clients if/and when deemed by the advisor to be appropriate to do so. With or without a written financial plan, clients will be provided with recommendations by their advisor based upon the analysis of their financial situation, objectives and risk tolerances. A comprehensive financial plan, if elected, may include, but is not limited to a net worth statement, a cash flow statement, a review of investment accounts including reviewing past asset allocations, providing asset repositioning recommendations, strategic tax planning, education planning with funding recommendations, a review of retirement accounts and plans including recommendations and one or more retirement scenarios, a review of insurance policies and recommendations for changes, if necessary and an estate planning review and recommendations. As previously stated, the Firm does not provide legal or accounting advice relative to its financial plans. It will, however, act as a facilitator in these areas between clients and their legal and/or tax advisors relative to the recommendations made in a financial plan. Detailed investment advice and specific recommendations are provided as part of a financial plan. Implementation of the recommendations is at the discretion of the client and may be implemented with either OSA or with a financial advisor of the client’s choosing. Consulting services are provided to clients regarding other financial-related concerns in situations where detailed or comprehensive financial planning is either not necessary or not desired. Common areas of concern addressed by these services include: Education planning Simple investment planning Death, disability and retirement planning Tax planning Net worth, cash flow and financial position Risk management (insurance) Other investment or non-investment issues Estate planning Investment Management Agreement Most clients choose to have OSA manage their assets in order to obtain ongoing in- depth advice and life planning. These clients are required to sign an Investment Management Agreement which defines the manner in which their assets will be managed and the fees assessed by the Firm. OSA’s Investment Management Agreement provides for cash flow management, insurance review, investment management, education planning, retirement planning, estate planning and tax planning, along with the implementation of recommendations within each area. Under the terms of the Agreement, investable assets are managed by the Firm in pursuit of the client’s goals in each of these areas. All aspects of the client’s financial affairs are reviewed, including those of their dependents, if any. Realistic and measurable goals are set and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. Key suitability parameters for each advisory client are developed with the client and clearly defined in an Investment Policy Statement and/or Client Risk Profile signed by the client at the outset of the advisory relationship or in similar suitability documents. These suitability documents are reviewed with clients on an annual basis and updated as necessary. Based on each client’s objectives and suitability factors identified in their suitability documents, the advisor will develop a plan with each client that focuses primarily on either income generation or growth of equity assets. Fees differ between these two portfolio management options and are listed in the respective advisory agreement presented to the client. Asset management fees are non-negotiable, as with the Firm’s other services. Asset management services are provided to OSA clients on a discretionary basis. Under the terms of our agreement, clients authorize the advisor to buy, sell, invest, reinvest, exchange and/or trade securities in their accounts at his/her sole discretion and without consulting with the client in advance. Advisory services are seen as ongoing and agreements are self-renewing unless terminated by either the client or the advisor. Fees and terms within the agreement, however, may be adjusted periodically to serve the client’s ongoing needs. Clients are notified in writing of any adjustments to their agreements. Fees are billed quarterly in advance and automatically deducted from the clients’ advisory accounts. Clients receive quarterly statements from their account custodian(s) which identify the account balance, fees deducted and, in some cases, the formula used in the calculation of the deducted fees. For clients terminating their advisory agreement prior to the end of a quarter for which they have been billed in advance, the Firm will provide a pro rata refund of fees paid in advance based upon the number of days remaining in the calendar quarter from the date the termination notice is received by the Firm. Refunded fees will be either credited back to the client’s advisory account prior to the transfer out of the account or a check forwarded directly to the client. Retainer Agreement OSA may, at its discretion, charge a retainer to clients for financial planning, consulting and/or asset management services. Should it do so, the retainer terms will be clearly stated in the agreement signed by the client. Asset Management A minimum account value is not required to open an advisory asset management account. Advisors generally recommend that clients allocate their investment assets to various vehicles deemed by the advisor to be appropriate and consistent with the client’s suitability and objectives. These investment vehicles may include, but are not limited to, the following: Exchange-listed securities Over-the-counter securities Foreign securities Warrants Corporate debt securities Commercial paper Certificates of deposit Municipal securities Mutual funds Exchange-traded funds U.S. Government securities Real estate partnerships Oil and gas partnerships Fees related to investment vehicles are clearly identified to the client, either by the advisor or by prospectus, prior to investing. Initial public offerings (IPOs) and private placements are available to clients through OSA as well, subject to pre- transaction approval of the Firm’s CCO. Securities transactions in advisory accounts are executed through Charles Schwab, OSA’s advisory client custodian. Other brokerage firms, broker/dealers and/or custodians may be utilized if requested by the client, known as client-directed brokerage, or if deemed to be more appropriate by the Firm. Under a client-directed brokerage arrangement, however, clients are advised that their direction may hinder OSA’s ability to achieve best execution on trades, negotiate commissions or participate in block trading which could be beneficial to the client. _______________________________________________________________________ Termination of Agreements Either OSA or the client may terminate any of the aforementioned agreements at any time by notifying the other party in writing thirty (30) days prior to the termination date. As previously stated above, clients terminating an asset management agreement prior to the end of a calendar quarter will receive a prorated refund of fees paid in advance based on the number of days remaining in the quarter. Since financial planning and consulting fees are billed upon completion of services, clients terminating from these types of agreements may be billed on a prorated basis using the Firm’s hourly billing rate of $250 per hour for the hours expended up to the date the termination notice is received from the client. In addition, OSA reserves the right to terminate any advisory engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in OSA’s judgment, to providing proper financial advice. Any unused portion of fees collected in advance will not be refunded to the client under these circumstances.