Chesme Capital Management (“Chesme” or “the Firm”) is an investment advisory firm registered with the U.S. Securities & Exchange Commission (“SEC”) under the name Chesme, LLC and is owned by Steven M. Erb and Douglas J. Vaughn. Chesme was established in 2003 and was registered with the SEC under the name Chesme, Inc. through June 2017, at which point it transitioned to Chesme, LLC as part of a reorganization. The Firm provides advisory services to individuals, institutional clients and retirement plans. Registration with the SEC does not imply a certain level of skill or training. The foundation of the Firm is its discipline and commitment to a fiduciary standard of care. Chesme practices nothing short of full disclosure and complete transparency. The Firm makes every effort to avoid conflicts of interest and make full disclosure of any material conflicts that could affect its advisory relationships. ADVISORY SERVICES - The Firm provides advisory services to individual clients in the form of Planning and Portfolio Management. The Firm provides advisory services to institutional clients in the form of Portfolio Management and to retirement plans in the form of Fiduciary Consulting and Investment Management. PLANNING (Individual Accounts) The Firm offers the following Planning services:
• Goals-Based Planning: The Firm develops and implements a prudent asset allocation strategy, targeting future financial goals and cash flow needs, while avoiding undue sacrifices to current lifestyle and unnecessary investment risk. The Firm focuses on existing and expected income sources/assets, investment time horizon, savings rate, and risk preference/capacity.
• Retirement Income Planning: The Firm develops a prudent and realistic retirement income strategy to support spending goals throughout retirement, while leaving sufficient reserves for unexpected contingencies and any desire to leave a legacy for subsequent generations. The Firm focuses on asset/liability balance, timing, and income strategy selection.
• Insurance Planning/Risk Management: The Firm works in conjunction with properly licensed insurance professionals to review existing insurance policies (Life, Disability, Long-term Care, Health, and Property & Casualty) and make recommendations as to the type, amount, and limits on each policy.
• Income Tax Planning: The Firm works in conjunction with properly licensed/certified accounting professionals to project current income tax position and analyze withholding. The Firm develops and implements strategies to reduce current and future income tax liability.
• Estate Planning: The Firm works in conjunction with properly licensed legal professionals to review existing estate planning documents and recommend changes where appropriate. The Firm projects estate taxes given current and proposed estate planning documents. PORTFOLIO MANAGEMENT (Individual/Institutional Accounts) The Firm provides Portfolio Management services to both individual and non-ERISA institutional accounts. Portfolio Management is offered as a standalone service or it may be used in conjunction with the Firm’s Planning services. The Firm gathers a sufficient level of relevant information concerning the client’s investment knowledge, current financial state, investment objectives, expectations, risk tolerance, and reasonable restrictions the client wishes to place on the management of the client’s assets. Chesme’s advice and portfolio management recommendations are specifically tailored to the goals, needs, and desires of each client on an individual basis. If the client opts to do so, the Firm may also offer advice on held away assets that are reported by client to the Firm. To enable the Firm to provide advice accurately, the client must utilize additional software allowing held away asset valuation to be disclosed to the Firm in order for the Firm to provide the most informed advice to client. Under this arrangement, the advice given to the client is based on a point in time for which the information is provided to the Firm. You are responsible for placing trades in held away accounts for which we provide investment advice, but do not maintain trading authority. Chesme will not provide portfolio management or execution services

on these accounts. The only additional fee for this service consists of a $37.50 per account per quarter account aggregation fee, to be billed quarterly in arrears. Chesme offers to meet with clients at least annually to review their financial circumstances and discuss any necessary adjustments to the current asset allocation. Clients are reminded to promptly notify the Firm of any changes to their financial situation, investment objectives, risk tolerance or account restrictions. In addition, the Firm assists the client in understanding and evaluating the services provided. THIRD PARTY MONEY MANAGERS Chesme will directly invest the assets deposited to your account(s) and/or strategically allocate them to separately managed accounts (each such account an “SMA”) to be managed by independent third-party money managers or sub-advisors (each a “TPMM”) in line with the asset allocation ranges we have determined for your portfolio. The asset allocation ranges for your portfolio may be modified over time, as your financial circumstances, needs, and investment objectives change. Chesme will communicate these changes to your TPMMs as necessary and modify your portfolio allocations accordingly. The TPMMs we recommend may contract with us directly to provide sub- advisory services to your account, may be accessible to us via the investment platform of your Custodian, or may contract with you independently. In some instances, you may be required to execute a separate written investment advisory agreement and/or discretionary trading authorization in favor of the recommended TPMM(s). You will be provided with the Form ADV Part 2A (or equivalent disclosures) for any recommended TPMMs in advance of their providing services to your account. Chesme will act as a co-advisor to each of your SMAs, periodically monitoring their performance, evaluating their initial and continuing suitability, and communicating changes in your investment profile to the TPMM, as necessary and appropriate. The TPMM shall be responsible for all trading and investment selection functions under this arrangement. Chesme, or a third-party engaged by Chesme, will conduct initial and ongoing due diligence on each recommended Chesme, negotiate fees to be paid by clients and other terms of the engagement, and will provide you with consolidated performance reporting of all of your SMAs. PONTERA Chesme uses a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows Chesme to avoid being considered to have custody of Client funds since Chesme does not have direct access to Client log-in credentials to affect trades. Chesme is not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Chesme will review the current account allocations. When deemed necessary, Chesme will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly, and allocation changes will be made as deemed necessary. FIDUCIARY CONSULTING & INVESTMENT MANAGEMENT (Retirement Plans) The Firm engages in Fiduciary Consulting & Investment Management for employer sponsored retirement plans at the Plan Level, Investment Level, and Participant Level. Duties include:
• Fiduciary Appointment Acceptance in Writing (as outlined by ERISA)
• Plan Fee Analysis
• Investment Policy Statement Preparation/Monitoring
• Vendor Search
• Vendor Pricing Negotiation
• Investment Selection/Monitoring
• Investment Performance Benchmarking/Reporting
• Participant Education, Guidance, or Advice ASSETS UNDER MANAGEMENT AND ADVISEMENT As of December 31, 2023, the Firm had a total of $648,568,328 discretionary assets under management and $0 in non-discretionary assets under management.