Description of Advisory Firm Vista Investment Management, LLC (“Vista”) is a privately-owned limited liability company based in Pittsburgh, Pennsylvania. Vista is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”). John Frankola founded Vista in 2002. Vista is an employee-owned business and is principally owned by Frankola Holdings, LLC. Advisory Services Offered Vista Investment Management provides investment management services for client accounts. These accounts are discretionary—that is, a client grants the investment adviser discretion by signing an Investment Advisory Agreement. This discretionary authority permits the investment adviser to buy or sell investments for a client's account without prior, specific authorization from the client apart from the constraints of suitability and any reasonable, prior restrictions that client may specify for investments. Vista provides investment management services for a small number of non-discretionary accounts only in situations where the qualified client has other discretionary accounts under management. For non- discretionary accounts, the client performs recommended changes to investment allocations at the advice of the adviser. Vista provides investment management services to individual and institutional clients. Vista utilizes a highly disciplined investment process to manage portfolios in accordance with each client’s specific objectives and risk tolerance. As the initial step in the investment process, Vista works with each client to determine investment

goals, objectives, risk tolerance, and current financial condition, which may be documented in a Client Questionnaire. This information is then incorporated into the client’s Investment Policy. These documents allow Vista to assess client suitability for our discretionary investment management services. The Investment Policy specifies allowable investments and a targeted asset allocation. It also provides clients the ability to place restrictions on their accounts. The most common restrictions prohibit us from buying specific companies or types of companies. Once asset allocation targets are defined, the portfolio is rebalanced on an ongoing basis. The firm may contract with various persons, including other investment advisory firms and 401(k) plans, to provide them with research services. These services may include providing research and recommendations regarding specific companies, industries, ETFs, and mutual funds. Vista provides pension consulting services for one client. These services are limited in scope and primarily involve the analysis of the mutual funds available to 401(k) plan participants and the development of model portfolios that plan participants may reference when allocating funds to the available investment options. The fees Vista charges for these services are negotiable. As of March 28, 2024, Vista Investment Management managed $273.68 million of client assets. Of these assets, approximately $269.9 million were managed on a discretionary basis and approximately $3.8 million were managed on a non-discretionary basis.