Fountainhead AM, LLC (“FAM,” “firm,” “we,” “our,” “us,”) is an investment management firm founded in May 2017 that provides both discretionary and non-discretionary investment sub- advisory services to select independent and affiliated registered investment advisors (each an “Advisor”). The firm is affiliated with Fountainhead Capital Management, LLC, (“FCM”) an SEC-registered investment advisor, and is principally owned by Joseph Halpern, Marc Rock, and Scott Silver. The firm has set aside 25% of the firm’s equity as Class B units. We have granted approximately one-third of the Class B units. Should all Class B units be granted and fully vest (approximately 7.5% has vested to-date), Joseph Halpern, Mark Rock and Scott Silver would go from collectively owning 94.5% of FAM to owning 70.875%. Additional information about financial services affiliations and the equity compensation appears in Item 10. Services FAM offers investment advisory services on a discretionary basis, as well as back-office support solutions, to Advisors through its managed model program (the “Program”) and its investment platform (“Platform”). The Program employs a variety of securities (collectively, the “Investments”) in its Program, primarily exchange-listed securities, such as stocks and ETFs, as well as open-end mutual funds and fixed-income securities. Other securities may be selected for the models in the Firm’s discretion. FAM also offers recommendations concerning non-liquid alternative investments, such as private placements, or interval fund structures that do not provide daily liquidity, but generally seeks specific consent from the client prior to allocating a portion of the portfolio these alternatives. The Program and the related Platform are designed for Advisors seeking to gain efficiencies by allowing them to focus on primary policy and risk allocation decisions, while delegating the investment selection, portfolio construction, and implementation decisions to FAM. FAM also consults with Advisors on a non-discretionary basis about trading strategy, rebalancing, and tax optimization as part of its services. Where FAM is acting as a sub-advisor to an Advisor, the Advisor may allocate some or all of its clients’ assets to FAM. Customarily, the Advisor retains the responsibility for the relationship with its client, and determines the initial and ongoing investment, risk tolerance, and suitability requirements of its client. The Advisor provides this information to FAM when establishing its clients account(s) on the FAM Platform. The Advisor typically provides ongoing oversight of the allocations to FAM to confirm that the allocations continue to be consistent with the end client’s investment needs and objectives. In the ordinary course of business, FAM does not interact directly with the Advisor’s end client or otherwise update end-client information except as provided through Advisor. Once an Advisor allocates its clients’ assets to FAM, FAM may select, change or re-allocate such client’s assets among the offered models, subject to guidance provided to FAM by Advisor. FAM will manage or effect purchases, sales, or other transactions for individual accounts (each, an “Account”) allocated to FAM by Advisor. In managing the Account, FAM is specifically permitted to retain all or part of the existing investments or to liquidate such investments, in FAM’s discretion. FAM’s investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. Because the Investments used in the Program may change from time to time, clients and prospective clients should consult directly with their Advisor to discuss the current Investments being offered. Account Supervision FAM will supervise the Accounts in accordance with a client’s stated objectives (e.g., maximum capital appreciation, growth, income, or growth and income), risk tolerance, as well as tax considerations. Because some types of investments involve additional degrees of risk, they will be selected only when consistent with the client’s stated investment objectives, tolerance for risk, liquidity and suitability. Account Customization and Investment Restrictions Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. All transactions effected for an Account will be deemed to be suitable for an Advisor’s client in light of

the stated investment objectives and guidelines, unless written notice to the contrary is received by FAM within ten (10) business days following a client’s receipt of the custodian’s statement reflecting such transactions. In allocating their clients’ assets to FAM, Advisors agree to contact their clients at least annually to determine whether there have been any changes in such clients’ financial situations or investment objectives and whether such clients wish to impose investment restrictions or modify existing restrictions or otherwise amend their investment guidelines. Advisors agree to promptly notify FAM of any changes. FAM does not guarantee the future performance of any Accounts, any specific level of performance, the success of any investment decision or strategy, or the success of FAM’s recommendations in the Accounts. The investment and other decisions made by FAM for the Accounts are subject to various market, currency, economic, political and business risks, and may result in investment decisions that will not be profitable. Non-Discretionary Services FAM may offer investment advice on a non-discretionary basis through a non-discretionary investment program in which all investment decisions are made by the Advisor. Advisors may use the FAM platform to assist with their own review and evaluation of the Advisor’s client’s investment objectives. Advisors may then receive recommended investment portfolios from FAM that the Advisor is free to implement, adjust, or simply provide to Advisor’s client for subsequent consideration by client. As requested by Advisor, FAM will also provide an asset allocation analysis. As the Advisor obtains revised information from the client, Advisor may use the FAM platform to generate revised investment recommendations. Advisor may also use the FAM platform to obtain recommendations for rebalancing of the client’s asset allocation. In providing non-discretionary services, FAM has no responsibility for executing transactions, implementing advice, or providing ongoing monitoring. The Advisor is solely responsible for requesting FAM’s review or recommendation. Written Agreement FAM will enter into a written Sub-Advisory Agreement (the “Agreement”) with each Advisor, which describes the nature and extent of FAM’s services, the terms and conditions applicable to such services, and the fees to be charged. Advisors are responsible for ensuring that their own client agreements provide for Advisor’s discretionary allocation to sub-advisors such as FAM and for assessment of the fees due to FAM. The services and fees described in this Brochure may not all be applicable to an Advisor’s specific Agreement. In the event of any difference between the information in this Brochure and the Agreement, the Agreement will control. Advisors will receive a copy of this Brochure prior to the execution of the Agreement. When an Advisor signs an Agreement with FAM, the Advisor’s relationship is serviced by a registered investment adviser representative of FAM. The Agreement may be canceled by either party at any time, for any reason, upon receipt of thirty (30) days prior written notice. If the Agreement is terminated, the Advisor will receive a prorated refund of any pre-paid fee, based upon the number of days remaining in the billing period after the termination date. The Advisor are not charged a liquidation fee by FAM if securities are to be delivered in-kind. The custodian may charge a liquidation fee. Use of Affiliated Funds Our models previously made some use of mutual funds advised or sub-advised by Exceed Advisory, LLC (“Affiliated Funds”). While we ceased using the Affiliated Funds in our models in 2023, some portfolios will continue to retain them for client-specific reasons. See information concerning the conflicts this presents, as well as the related fees, in Items 5 and 10, below. Wrap Accounts FAM does not offer wrap accounts. A wrap account is structured such that a client pays a single fee, or single percentage fee which covers both investment advisory services and brokerage costs. Disclosure Statement A soft copy of FAM’s Brochure will be provided to each Advisor prior to, or contemporaneously with, the execution of the Agreement. The Advisor is responsible for delivering a copy to its own client. Assets Under Management As of December 31, 2023, FAM had approximately $739.2 million in discretionary assets under management.