A. General Description of Christy Capital Management, LLC Christy Capital Management, Inc. (“CCM”) is an SEC-registered investment advisor, with its principal offices located in Macon, Georgia. CCM has been in business since December 14, 2005, and the firm’s principal owner is Brandon S. Christy. Christy Capital Management, Inc. and its representatives are engaged in the business of providing financial, investment advisory and insurance services to its customers. In this capacity, we also operate as a state licensed insurance agency and investment advisory firm in the states in which we are properly licensed to conduct business. In January 2018, the firm transitioned from state registration to SEC registration. B. Description of CCM’s Advisory and Related Services CCM provides the following advisory services to its clients: ▪ Investment Advisory and Wealth Management Services ▪ Federal Employee Benefit Analysis ▪ Estate Conservation ▪ Tax Planning ▪ Retirement Strategies ▪ Insurance and Annuity Products (Non-variable) ▪ Financial Reviews For Investment Advisory and Wealth Management Services, CCM will, based on a client's individual circumstances and needs, recommend an investment program to the client. CCM is able to develop an investment recommendation that are tailored to our client’s need by closely communicating with clients. CCM listens carefully to our client’s needs and characteristics to design an investment plan that aligns with the client’s vision, values and objectives. 5 | P a g e Factors considered in making these recommendations include account size, risk tolerance, the opinion of each client, client’s individual objectives and needs, and CCM’s investment philosophy. CCM will assist the client in reviewing the client's income and expenditures, investment objectives, risk tolerance, liquidity requirements, investment restrictions and other relevant factors. CCM recommends various types of investments, typically mutual funds, ETFs, and annuities. CCM offers a combination of the following advisory services, where appropriate, to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations and corporations or other business entities. Co-Advisor Program CCM recommends certain third-party investment managers (“Co-Advisors”) who are not affiliated with CCM to design and manage model portfolios for client assets. CCM assists clients in completing a client profile questionnaire and then reviews the information. The firm will then recommend a Co-Advisor and corresponding model portfolio that aligns with the disclosed risk tolerance and investment objectives. CCM will enter all asset allocations on behalf of the client into the selected Co-Advisor platform. In a co-advisor relationship, also known as a “dual contract arrangement, the client enters into an investment advisory agreement with CCM and a separate agreement with the third- party investment manager. The client hires CCM to provide initial and ongoing investment advisory advice and recommendations. The client hires the third-party manager to manage the selected portfolio for the benefit of the client. CCM currently has co-advisory relationships with:
• Beacon Capital Management Depending on the client’s needs, CCM recommends Beacon Capital Management (“Beacon”) to manage their assets. Beacon provides model portfolios comprising a diverse group of exchanged-traded funds (“ETFs”) and mutual funds (“Funds”). Beacon will invest the Client assets into the model portfolio strategy recommended by CCM and approved by the client. Beacon Capital Management manages the portfolio for the Client based upon the investment objectives, constraints, and philosophy of the portfolio selected by the client. Beacon or the custodian of the client’s assets also provides to the client, at least quarterly, an account statement.
• Orion Portfolio Solutions Based upon the needs of the client, CCM recommends Orion Portfolio Solutions (previously 6 | P a g e “FTJ FundChoice,”) to manage assets. Upon the client’s approval of CCM’s recommendations, client assets will be invested in the Orion Portfolio Solutions (“Orion”) model portfolio strategy indicated based upon client’s investment goals and needs. Orion will manage the assets according to the selected portfolio strategy. Whether the client is invested with Beacon Capital Management or Orion Portfolio Solutions, Christy Capital Management does not have discretionary authority to make trades in the client’s account. Under their separate contract with Beacon or Orion, the client does grant Beacon or Orion discretionary authority to make trades within the client’s account without Beacon or Orion seeking the client’s pre-approval. CCM will obtain the client’s consent before moving client assets between various Co- Advisor platforms or between the model portfolios provided by the Co-Advisor. The Co- advisor will implement the model for the client’s account by acquiring the fund shares that are represented in the selected model portfolios. We will be available to answer questions that you may have regarding your account and act as the communication conduit between you and the Co-Advisors. You should be aware that there may be other Co-Advisor managed programs and other third-party managers not recommended by our firm that are suitable for you and that may be less costly than arrangements recommended by CCM.
• Retirement Plan Services Where a client has engaged CCM to provide retirement plan services, we will provide non- discretionary investment advisory services to Client as outlined in ERISA §3(21), as well as plan participant education. In general, we divide the ERISA §3(21) fiduciary responsibilities with another registered investment advisor, such as PHD Retirement Solutions, with whom the client will have a separate contractual relationship. In such cases, we and the other registered investment advisor will split the §3(21) fee. Subadvisor Program For clients who grant CCM discretionary authority over their assets, CCM contracts with certain third-party investment managers who are not affiliated with CCM to design and manage model portfolios. Unlike the co-advisor program described above, the client does not have a direct contractual relationship with the third-party manager. Instead, CCM selects and contracts with that manager or managers in what is called a subadvisor relationship. CCM assists clients in completing a client profile questionnaire and then reviews the information provided. The firm will then either recommend a Co-Advisor program, as described above, or and the subadvisor program described here, corresponding to the 7 | P a g e client’s disclosed risk tolerance and investment objectives. CCM delegates discretionary authority to the subadvisor to manage assets, but retains the authority to hire or terminate any manager. Because clients grant CCM discretionary authority in the subadvisor program, CCM will not obtain the client’s consent before hiring or terminating any subadvisor or reallocating assets between subadvisors. CCM currently has a subadvisor relationship with EverSource Wealth Advisors, LLC, which designs and manages model portfolios for CCM and provides such back-office services as reporting, billing, compliance consulting, and assistance with technology. For information about the costs associated

with these Co-Advisor and subadvisor programs, please see Item 5. No guarantees can be made that your financial goals or objectives will be achieved through the managed account program or by a recommended/selected Co-Advisor or subadvisor. Further, no guarantees of performance can ever be offered by our firm. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more details.) Rollover Recommendations For clients who are participants in a retirement plan, we will evaluate whether it is in their best interest to “roll over” their plan account to an individual retirement account (“IRA”), move their assets to a different retirement plan, leave the plan as is, or reallocate the assets in the plan account. CCM will generally earn a fee if the client elects to rollover the plan account or to contract with CCM for the provision of investment advice on the plan account assets. This creates a conflict of interest and an incentive for CCM to recommend a rollover rather than leaving the account as is. CCM discloses this conflict, advises the client of its fiduciary status and documents the rationale for any rollover recommendation. This is true as well when CCM recommends Retirement Management Systems, Inc. (described below). Recommendation of Other Advisors For individuals who are participants in a retirement plan, CCM takes the client through a risk tolerance questionnaire and, in some cases, recommends the client consider engaging Retirement Management Systems, Inc. (“RMS”), an unrelated registered investment advisor, to manage their plan account. CCM only makes such a referral where it is in the best interest of the plan participant and where RMS’s advisory fees are reasonable, as documented in CCM’s records. RMS pays CCM a solicitation fee for such referrals pursuant to a written agreement which requires CCM to deliver RMS’s Form ADV Part 2A and to obtain the client’s 8 | P a g e signature on a statement disclosing the solicitation relationship and fee. RMS’s advisory fee charged to a referred client is not increased as a result of the payment of a referral fee to CCM. Until June 2017, CCM was in a solicitation relationship with Beacon Capital Management under which CCM referred clients to Beacon based upon an evaluation of the client’s circumstances and objectives. In that relationship, Beacon paid CCM an ongoing referral fee which was a percentage of the fee Beacon received from the client. Starting in 2017, CCM ended that solicitation arrangement as to future clients and requested that existing clients execute a Client Services and investment Management Agreement with CCM and a separate agreement with either Orion or Beacon. This is the dual contract or co-advisor relationship described above. While most CCM clients have transitioned to a co-advisor relationship, there are still some clients under the previous solicitation agreement. Each such arrangement is governed by a written agreement and complies with SEC Rule 206(4)-1 and applicable state securities rules and regulations. For those clients who are still under the Beacon solicitation arrangement, CCM is available to answer questions that clients have regarding their account and to act as the communication conduit between clients and the third-party money manager. Consulting Services CCM offers ongoing advisement consultations for clients regarding 529 college savings plans (included but not limited to Coverdell accounts). When providing these services, we review the client’s financial situation, goals and objectives, as well as the investment options available in the 529 plan. CCM will review the 529 plan account at agreed-upon intervals and will make recommendations from the list of available investment options in the 529 account as it deems appropriate and consistent with the client’s stated investment objectives and risk tolerance. The client should be aware that 529 college savings plans usually limit how often an account owner can reallocate existing assets within a 529 college savings plan account. The client must determine whether or not to implement CCM’s advice and implement any trades. CCM does have investment discretion over 529 plan accounts at American Fund. CCM also offers advice to clients regarding asset allocation benefits selections for clients regarding employment and retirement benefits. However, CCM does not offer investment advice for assets held in employer sponsored retirement plans (i.e. 401(k), 403(b), or TSP). At the client’s request, CCM may recommend a third party to manage portfolio models within these employer sponsored plans, such as RMS. The services under this Agreement do not constitute asset management services or asset advisory services for Client’s accounts; CCM will not have investment discretion or trading authority over Client’s accounts. Client will determine whether or not to implement CCM’s advice. These consultations will cease once Client has made benefits selections. The implementation of 9 | P a g e any asset allocations or benefits elections will be solely the responsibility of Client. Financial Reviews In 2022, CCM began offering a limited “financial review” to new clients for $500.00 as a service to those clients to help them obtain a better understanding of their financial situation and future. After signing the Financial Review Agreement, the client provides personal and financial information to CCM and CCM provides to the client a risk tolerance analysis, a financial goals review, the client’s current investment allocation, and an asset allocation blueprint. A CCM financial advisor then schedules a meeting with the client to present the information and answer questions. Clients who wish to engage CCM for additional planning, advisory or other services must execute CCM’s standard client agreement. Services Limited to Specific Types of Investments CCM limits its investment advice to mutual funds, ETFs, equities, bonds, fixed income, debt securities, third party money managers, REITs, insurance products including annuities, and government securities. CCM may use other securities as well to help diversify a portfolio when applicable. C. Client-Tailored and Client-Imposed Restrictions CCM offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client profile which outlines each client’s current situation (income, tax rates, and risk tolerance levels) and is used to construct a client-specific plan to aid in the selection of a portfolio that matches restrictions, needs, and goals. Clients may impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent CCM from adequately servicing the client account, or if the restrictions would require CCM to deviate from its standard suite of services, CCM reserves the right to decline or end the relationship. D. Wrap Fee Programs CCM does not presently participate in wrap fee programs. 10 | P a g e E. Assets Under Management As of January 2, 2024, our assets under management were as follows: Assets Managed on Discretionary Basis $232,644,160$9 6,934 $226 Assets Managed on Non-Discretionary Basis $26,948,943 Total Assets Under Management $259,593,103