Business Description We provide services to individuals and high-net-worth individuals concerning mutual funds, fixed income securities, real estate funds (including public REITs), equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds and non-U.S. securities. As a registered investment adviser, we are held to the highest standard of client care – a fiduciary standard. As a fiduciary, we always put our client’s interests first and must fully disclose any potential conflict of interest. We do not hold customer funds or securities. Registration as a “registered investment adviser” does not imply a certain level of skill or training. A. Description of the Advisory Firm May Barnhard Investments, LLC dba MBI LLC (hereinafter “MBI LLC”) is a Limited Liability Company organized in the State of Maryland. The firm was formed in November 2013, and the principal owner is Councilor, Buchanan & Mitchell, P.C. B. Types of Advisory Services Portfolio Management Services MBI LLC offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. MBI LLC 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 to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring MBI LLC evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. MBI LLC 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. MBI LLC will also provide investment advisory services to clients on a non-discretionary basis. MBI LLC seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of MBI LLC’s economic, investment or other financial interests. To meet its fiduciary obligations, MBI LLC attempts to avoid, among other things, investment or trading practices that systematically advantage

or disadvantage certain client portfolios, and accordingly, MBI LLC’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is MBI LLC’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Services Limited to Specific Types of Investments MBI LLC generally limits its investment advice to mutual funds, fixed income securities, public REITs, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds and non-U.S. securities, although MBI LLC primarily recommends mostly mutual funds and ETFs, generally in U.S. securities, balanced across all capitalizations, to a majority of its clients. MBI LLC may use other securities as well to help diversify a portfolio when applicable. 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. C. Client Tailored Services and Client Imposed Restrictions MBI LLC will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by MBI LLC on behalf of the client. We will consider the client's investment preferences in addition to risk, where we consider it appropriate. MBI LLC may use preferred investments together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Beyond the inherent restrictions based on a client’s suitability/risk tolerance profile, clients of MBI LLC may impose further restrictions (e.g., in accordance with their values or beliefs) on investing in certain securities or types of securities. Any such restrictions shall be documented in the investment policy of the agreement. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. MBI LLC does not participate in any wrap fee programs. E. Assets Under Management MBI LLC has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 277,684,339.00 $ 18,145,927.00 12/31/2023