Touchstone Capital, Inc. (hereinafter “TCI”) is a Corporation organized in the State of Pennsylvania. The owner of TCI is Touchstone Capital Ventures, Inc. The firm was formed in July 2000 and became registered as an investment adviser in 2016. Prior to registration as an investment adviser, TCI provided insurance services (which it continues to do) and served as the entity through which Theodore Stephen Kerr paid expenses and received income as representative of Commonwealth Financial Network. (herein after “Commonwealth”) Types of Advisory Services Investment Management Services TCI offers ongoing investment management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. TCI 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. Investment management services include, but are not limited to, the following:  Investment strategy  Personal investment policy  Asset allocation  Asset selection  Risk tolerance  Regular portfolio monitoring  Variable Annuity Insurance Products  Qualified Tuition Plans TCI evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. TCI will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction; however, TCI will also accept non-discretionary accounts for which TCI will secure client permission prior to proceeding with any transactions. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Investment decisions are made in accordance with the fiduciary duties owed to its clients and without consideration of TCI’s economic, investment or other financial interests. To meet its fiduciary obligations, TCI attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, TCI’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 TCI’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. The account is monitored by your advisor on a regular basis, and your advisor will meet with you no less than annually to review the account’s holdings and performance. Commonwealth’s PPS Select Program TCI has entered into an agreement to offer clients access to certain programs offered by Commonwealth, an SEC- registered investment adviser. Commonwealth is the sponsor of PPS Select. The PPS Select program offers a variety of model portfolios from which investors may choose. The PPS Select model portfolios are created and managed by Commonwealth’s Investment Management and Research team. The client’s financial advisor will help the client determine which PPS Select models are best suited for the client based on his or her risk profile, investment objectives, and preferences, leaving the actual investment decisions to Commonwealth’s Investment Management and Research team. PPS Select offers a variety of model portfolios with varying investment product types, including mutual fund and ETF portfolios, fixed income portfolios, and variable annuity sub-account portfolios. The account is monitored by your advisor on a regular basis, and your advisor will meet with you no less than annually to review the account’s holdings and performance. Wealth Management Services Wealth management services may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Investment planning involves working with clients to make sure their investments match their respective risk tolerance and goals. Tax concerns are addressed by working with the client to determine and compare effective tax rates for income, capital gains and other earnings or investments, then attempting to allocate the client’s resources accordingly. Life insurance planning entails reviewing the life insurance and/or disability insurance needs of the client, together with any applicable dependents, spouse, or other relatives, and assessing appropriate coverage for these individuals. College planning entails helping clients save for higher education, whether for the client or his/her children or other dependents, in the ideal manner to suit the client’s overall financial goals and means. Wealth management services for retirement planning entails making sure clients are financially equipped for retirement in light of the client’s anticipated income and expenses, investments, and other assets. Debit/credit planning consists of breaking down client budgets and aiding clients in decision-making as to current debt, anticipated significant expenses and potential debt, and avoiding excessive debt. Retirement Plan Consulting TCI offers its advisors a fee-for-service consulting program whereby advisors may offer one-time or ongoing advisory services to qualified retirement plans. Clients may engage TCI advisors for Retirement Plan Consulting services on a negotiated hourly, flat, fixed, or asset-based fee basis. The maximum annual account consulting fee, when stated as a percentage of assets, is 2.50% and is negotiable. Fees may be paid at the time of service, in advance of service, or after service has been rendered. Through the Retirement Plan Consulting program, advisors assist plan sponsors with their fiduciary duties and provide individualized advice based upon the particular needs of the plan and/or plan participants regarding investment management matters, such as: investment policy statement support, investment selection and monitoring, overall portfolio composition, and participant advice programs. Services Limited to Specific Types of Investments TCI generally limits its investment advice to mutual funds, fixed income securities, insurance products including annuities, equities, ETFs (including ETFs in the gold and precious

metal sectors), treasury inflation protected/inflation linked bonds, non-U.S. securities, venture capital funds and private placements. TCI may use other securities as well to help diversify a portfolio when applicable. Client Tailored Services and Client Imposed Restrictions TCI 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 TCI on behalf of the client. TCI may use “model portfolios” together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. Each client is evaluated based on a number of factors including, but not limited to, age, health, net worth, income, savings rate, tax rates, upcoming extraordinary expenses, job reliability (if working), time horizon to major financial goals, past investment experience, and knowledge related to investing. There are a number of data collection tools that are used throughout our formal interview process to evaluate each client based on the above criteria. Wrap Fee Programs A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. TCI’s Investment Management Services and Commonwealth’s PPS Select Program are considered “wrap fee” programs in which the client pays a specified fee for portfolio management services and trade execution. Wrap fee programs differ from non-wrap fee programs in that the fee structure for wrap programs is intended to be largely all-inclusive, whereas non-wrap fee programs assess trade execution costs in addition to the asset management fee. TCI’s Investment Management Services wrap fee program is managed by your TCI financial advisor, and Commonwealth’s PPS Select wrap fee program is managed by Commonwealth’s Investment Management and Research team. For more information on TCI wrap fee program, please refer to the TCI Wrap Fee brochure. For more information on Commonwealth’s wrap fee program, please refer to Commonwealth’s Wrap Fee brochure (Appendix 1 in their ADV 2A). For the investment advisory services provided to you, TCI and Commonwealth, along with your financial advisor, each receive a portion of the investment advisory fee you pay when you participate in any managed account program. As part of our financial planning and advisory services, we may provide you with recommendations and advice concerning your employer retirement plan or other qualified retirement account. When appropriate, we may recommend that you withdraw the assets from your employer’s retirement plan or other qualified retirement account and roll the assets over to an individual retirement account (“IRA”) to be managed by our firm or a Third- Party Manager that we recommend. If you elect to roll the assets to an IRA under our management, we will charge you an asset-based fee as described in Item 5. This practice presents a conflict of interest because our Advisory Representative has an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have your IRA assets managed under our program or a Third-Party Managed Program. You have the right to decide whether to complete the rollover and the right to consult with other financial professionals. In addition to complying with applicable SEC rules, TCI is subject to certain rules and regulations adopted by the U.S. Department of Labor when we provide nondiscretionary investment advice to retirement plan participants and IRA owners. When these DOL rules apply, our advisors and Touchstone Capital are “fiduciaries,” for purposes of the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended, and the Internal Revenue Code of 1986 (“the Code”), as amended. Therefore, TCI and our advisors may not receive payments that create conflicts of interest when providing fiduciary investment advice to plan sponsors, plan participants, and IRA owners, unless we comply with a prohibited transaction exemption (“PTE”). Beginning December 20, 2021, TCI and our advisors will comply with ERISA and the Code by using PTE 2020-02. As fiduciaries under ERISA and the Code, we render advice that is in plan participants’ and IRA customers’ best interest. TCI’s and our advisors’ status as an ERISA/Code fiduciary is limited to ERISA/Code covered nondiscretionary advice and recommendations regarding rolling over a retirement account and does not extend to all situations. The specific advisory program you select may cost you more or less than purchasing program services separately. Factors that bear upon the cost of a particular advisory program in relation to the cost of the same services purchased separately include, but may not be limited to, the type and size of the account; the historical or expected size or number of trades for the account; the types of securities and strategies involved; the amount of fees, commissions, and other charges that apply at the account or transaction level; and the number and range of supplementary advisory and client-related services provided to the account. Lower fees for comparable services may be available from other sources. Investment recommendations and advice offered by TCI and its advisors do not constitute legal, tax, or accounting advice. Clients should coordinate and discuss the impact of the financial advice they receive from their advisor with their attorney and accountant. Clients should also inform their advisor promptly of any changes in their financial situation, investment goals, needs, or objectives. Failure to notify the advisor of any material changes could result in investment advice not meeting the changing needs of the client. TCI has the following assets under management: Discretionary Accounts: Non-discretionary Accounts: Date Calculated: $146,440,144.35 $0.00 December 31, 2023