Firm Description and Types of Advisory Services Early McClintic & McMillan, LLC is an investment adviser providing wealth services. We provide investment advisory services to individuals, families, high net worth individuals, retirement plan sponsors, and foundation trustees. These services include financial planning services, portfolio management services, pension consulting services, and the selection of other advisers. Early McClintic & McMillan is a limited liability company organized under the laws of the State of Texas in 1997. The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the terms "we," "our," "firm," "us," and “EMCMC” refer to Early McClintic & McMillan, LLC, and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. You may also see the terms Associated Person or “investment advisor representative” throughout this brochure. This term refers to our officers, directors, and other personnel who provide investment advice on behalf of our firm. The term “portfolio” refers to all your accounts collectively managed under a discretionary or non- discretionary portfolio management program. Prior to engaging EMCMC to provide any services described below, the client will be required to enter into one or more written agreements with EMCMC setting forth the terms and conditions under which we shall render our services. Principal Owners EMCMC is owned by Richard Early, Scott McClintic, Dan McMillan, Ian McClintic, David Huddleston, and Zachary Azra. Types of Advisory Services EMCMC offers the following types of advisory services: discretionary and non-discretionary portfolio management, financial planning, pension consulting services, the selection of third-party money managers, and Separately Managed Accounts (“SMAs”).
• Discretionary and Non-Discretionary Portfolio Management EMCMC offers discretionary and non-discretionary portfolio management services based upon the individual goals, time horizons, liquidity needs and risk objectives of each client. 8 Early McClintic & McMillan, LLC We will create a portfolio consisting of one, some, or all of the following: mutual funds, exchange- traded funds (“ETFs”), closed-end funds, individual equities and bonds, and other investment products, as appropriate. EMCMC will allocate your assets among various investments taking into consideration your overall management style and objectives. Mutual funds will be selected on the basis of any or all of the following factors, including, but not limited to the fund’s performance history, industry sector in which the fund invests, the track record of the fund manager, the fund’s investment objective, the fund’s management style, and the fund’s management fee structure. We may use third party managers to manage a portion of the assets in your account. We will regularly monitor the performance of third-party managers. Once the appropriate portfolio has been determined, we will review the portfolio at least quarterly and if necessary, rebalance the portfolio based upon your individual needs and stated goals and objectives. Each client can place reasonable written restrictions on the types of investments to be held in the portfolio. Clients are requested to keep us informed of any changes in their financial or personal circumstances that could affect our management of their account(s). Clients maintain individual ownership of all securities in their account(s). When appropriate, EMCMC may recommend the use of margin and/or option transactions. As these investment strategies involve a certain degree of additional risk, they are only recommended when consistent with the client objectives and risk tolerance. While a negative amount may show on your statement for the margined security as the result of a lower net market value, the amount of the fee is based on the absolute market value. This poses a conflict of interest where EMCMC benefits from the use of margin creating a higher absolute market value and therefore increasing its fee. The use of margin also results in interest charges in addition to all other fees and expenses associated with the security involved. We manage this conflict through disclosure and through policies that require us to act in the client’s best interest. EMCMC may request to consult with and obtain information from the client’s accountant and/or attorney. It is at our discretion to determine the value or relevance of the information received and we are under no obligation to rely solely on this information. In a non-discretionary arrangement, we must obtain the client’s approval prior to our placing each transaction on your behalf with your custodiam purchasing or selling any securities. Non- discretionary account clients in all cases make the final decisions regarding transactions, even in cases where EMCMC facilitates the communication with the client’s custodian. Accordingly, non- discretionary clients may forego a particular recommended transaction, or a particular transaction may be delayed, if we cannot obtain the client’s prior consent. Clients that participate in discretionary portfolio management services, provide our firm with written discretionary authority to manage your account, consistent with their investment objectives and risk profile. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for a client’s account without the client’s approval prior to each transaction. Clients may limit our discretionary authority (for example, limiting the types of securities that can be purchased. 9 Early McClintic & McMillan, LLC The type of authority governing the relationship, whether discretionary or non-discretionary, any investment restrictions and the terms and conditions governing the advisory arrangement are set forth in the Investment Advisory Agreement signed by each client. We are held to a fiduciary standard that covers the entire investment advisory relationship with you. For example, we are required to monitor the client’s portfolios, investment strategy and investments on an ongoing basis. We are required to identify and eliminate conflicts of interests or disclose them, so that you can decide whether or not to agree to them.
• Raymond James Consulting Services (“RJCS”) and Selection of Other Investment Advisers We may recommend the use of the RJCS Separately Managed Account (“SMA”) program. As program sponsor, RJCS enters into a sub-advisory agreement with selected affiliated and unaffiliated SMA Managers. RJCS serves as a conduit through which clients may access several nationally known money management firms for account sizes below normal firm minimums. All managers hired have passed an in-depth quantitative and qualitative screening process and are subject to on-going monitoring by the Raymond James Asset Management Services (“AMS”) Manager Selection & Due Diligence team. Clients in the RJCS SMA program select money managers to individually manage their accounts on a discretionary basis or provide model portfolio recommendations. We believe that the RJCS SMA program will provide clients with access to high quality investment management firms. SMA accounts are typically employed by clients that wish to maintain greater control over asset allocation. While SMA’s are like a mutual fund in that a client pays a fee for management of their designated investments, an important difference is that SMA’s generally provide clients the ability to segregate their assets from other investors. That is, the client directly owns the portfolio securities versus a mutual fund investor owning shares in an investment company that in turn owns the “pooled” investments. There are however, some SMA’s in the RJCS program that hold “pooled” investments. SMA clients can impose reasonable restrictions on the investments made in their account, contribute, or withdraw securities and/or cash from their account, request the sale of individual securities for tax planning purposes. Depending on the arrangement selected, the SMA Manager may develop and execute portfolio transactions or supply a model portfolio to Raymond James & Associates (“RJA”) and RJA or an RJA affiliate executes the portfolio transactions. You will appoint RJA or an affiliate, as sub-adviser, to select certain portfolio managers, monitor performance of your account, provide you with accounting and other administrative services, and assist portfolio managers with certain trading activities. We will assist you in selecting an appropriate manager(s) based upon your financial needs and investment objectives. Furthermore, we will receive a portion of the fee that is calculated and collected by RJA. The manner in which fees are 10 Early McClintic & McMillan, LLC collected by RJA is separate and distinct from and does not have any bearing on the advisory fee you pay EMCMC. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the manager's performance, methods of analysis, fees, your financial needs, investment goals, time horizons, liquidity needs and risk objectives. We will periodically monitor the manager’s performance to ensure its management and

investment style remain aligned with your investment goals and objectives. RJA and the manager(s) will actively manage your portfolio and will assume discretionary investment authority over your account. Although we have the discretionary authority to hire and fire manager(s) and/or reallocate your assets to other managers, we will attempt to discuss these changes with you prior to implementation.
• Raymond James Trust Services Raymond James Trust, N.A. (“RJ Trust”), established in 1992, is a wholly owned subsidiary of Raymond James Financial and manages more than $8 billion in assets. RJ Trust allows advisors to manage client assets using comprehensive trust services and products. Our clients can utilize the trust services of RJ Trust for a full array of trust structures, such as living trusts, charitable remainder trusts, life insurance trusts, and specialty trusts. We serve as the trust’s investment advisor and work in concert with the trust officer at RJ Trust, which will serve as the trustee, co-trustee, personal representative, or agent to the trustee. We will remain your point of contact and will manage your assets with an insight into your full financial picture. As your investment manager, EMCMC will establish and monitor asset allocation, review, and recommend trades, track and monitor investment performance, and provide investment performance reports. Our services are provided on a non-discretionary basis meaning that we make recommendations to RJ Trust which makes all final decisions. You are under no obligation to utilize RJ Trust and EMCMC will work with your trust provider. Using a different trust provider may be more or less expensive than working with RJ Trust. Stand Alone Financial Planning Services EMCMC offers financial planning services, which may include a review of all aspects of a client’s current financial situation, including the following components: cash management, risk management, goal setting, and retirement planning. Clients understand that when we are engaged to address only certain components, the client’s overall financial and investment issues may not be taken into consideration. We meet with you to review risk tolerance, financial goals and objectives, and time horizons. Additional meetings may include a review of additional financial information, sources of income, assets owned, tax returns, investments, and personal and family obligations. The financial plan may 11 Early McClintic & McMillan, LLC include both long and short-term considerations, depending upon the individual scenario. Upon completion, you will be provided with recommendations that are deemed to be compatible with your stated goals and objectives. An implementation schedule is reviewed with you to determine which steps will be pursued, and with whom the steps may be accomplished. You are under no obligation to utilize additional services of EMCMC and its advisors, and you are under no obligation to implement the advice or plan. Clients may choose all or certain components of advice and recommendations and can implement the recommendations through the service providers of their choice. Pension Consulting Services We offer pension consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing consulting. These pension consulting services will generally be non-discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary. We may also assist with participant enrollment meetings and provide investment-related educational sessions to plan participants on such topics as:
• Diversification • Asset allocation • Risk tolerance • Time horizon Our educational sessions may include other investment-related topics specific to the particular plan. We may also provide additional types of pension consulting services to plans on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant- level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents. Retirement Account Rollovers We offer recommendations and advice concerning employer retirement plan or other qualified retirement accounts. Our recommendations may generally include that the client consider withdrawing the assets from his/her employer's retirement plan or other qualified retirement account and roll the assets over to an Individual Retirement Accounts (“IRA”) or other qualified investment vehicle. If a client elects to roll the assets to an IRA that is subject to our management, we will charge an asset-based fee as described above under Item 5 below. This poses a conflict of interest because we have an incentive to recommend a rollover for the purpose of generating compensation rather than solely based on the client’s needs. As a fiduciary, we are required to 12 Early McClintic & McMillan, LLC always act in the client’s best interests. Clients are under no obligation, contractually or otherwise, to rollover their retirement assets, or to have their assets rolled into an IRA managed by us. It is important for clients to understand that many employer retirement plan sponsors permit former employees to keep their retirement assets in their company plan, even after the employee terminates their employment with the company or retires. In determining whether to rollover employment retirement plan assets to an IRA or other investments vehicle, clients should consider the costs and benefits of each option. Employees will typically have the following options:
• Leave the funds in the employer's (or former employer's) plan
• Move the funds to the new employer's retirement plan
• Withdraw the funds from the plan, which results in a taxable distribution and a taxable event
• Rollover the funds into an IRA rollover account Before making any changes to their plan, we encourage clients to carefully consider any tax implications with their accountant or tax advisor. Below are some general 401K Plan features and differences versus an IRA that clients should consider:
• Although employer retirement plans may have a more limited investment menu than the investment options available in an IRA, the plan may also have unique investment options not available to the public, such as the opportunity to invest in the employer’s securities if the employer is a publicly traded company.
• The employer retirement plan may offer financial advice, guidance, and/or model management or portfolio options at no additional cost, or at a fee which may be lower than our advisory fee.
• Clients should understand the various investments available in an IRA and the costs.
• In some cases, the employer retirement plan may allow participants to hire us as manager and keep the assets titled in the plan’s name.
• Clients interested in investing only in mutual funds should understand the cost structure of the share classes available in the employer's retirement plan and how the costs of those share classes compare with those available in an IRA.
• It may be possible to take out a loan on 401k Plan assets. This option is not available for IRAs.
• It may be possible to delay taking 401k Plan or retirement account minimum distributions beyond age 72.
• A 401k Plan may offer more liability protection than a rollover IRA. Although IRA assets are generally protected from creditors in bankruptcies, it depends on state law and there can be some exceptions to the general rules.
• IRA distributions are subject to ordinary income tax and may also be subject to a 10% early distribution tax penalty. There are certain exceptions available based on age, disability, or if the assets are used to pay for higher education expenses or to purchase a home. 13 Early McClintic & McMillan, LLC It is important that clients understand the differences and options available as well as the cost and tax implications to be able to decide whether an IRA rollover is appropriate. Information for all clients Each client is advised that it remains such person’s responsibility to promptly notify us if there is ever any change in the client’s financial situation or investment objectives for the purpose of reviewing, evaluating, or revising EMCMC’s previous recommendations and/or services. Changes in tax laws or regulations may occur at any time and could substantially impact your situation. While we are familiar with the tax provisions of the issues presented to you, we are not qualified to render advice on tax or legal matters, nor will EMCMC prepare any actuarial, legal, or accounting documents. Assets Under Management As of December 31, 2023, EMCMC managed assets of $504,757,275, of which $304,036,651 are managed on a discretionary basis, $200,720,624 are non-discretionary assets under management, and $15,813,525 are assets under advisement.