Section AFalcon Capital Management, Inc. (hereinafter referred to as the “Advisor”) was formed under the corporate name of Asset Quant, Inc. in July of 1989 for the purpose of financial planning. The firm name was subsequently changed to its present name in and around 1994 and the focal point of the business was amended to portfolio management within the guidelines of financial objectives. The principal owner of the firm is Robert C. Dalldorf (100% of stock) and he is President and Chief Compliance Officer. Section B The Advisor provides investment advisory services to clients that consist of individuals, families, trusts, companies and retirement plans on a fee basis. Clients communicate to the Advisor their financial goals, time frame and financial assets with which to achieve these goals. Clients designate those assets to be managed by the Advisor who structures an internal investment policy which consists of a macro asset allocation across asset classes which may or may not fully consist of U.S. Equity, International Equity, Low Correlation, Taxable Fixed Income and Tax Exempt Fixed Income. The allocation is the recommendation of the Advisor and is discussed openly with the client. The allocation may change with market conditions, Client input, be limited to a range or be adjusted by the Advisor at any given time. The goal of the investment program structured by the Advisor may be achieved on a short term basis (1 to 3 years) or a long term basis (3 to 5 years) or longer. For the most part, the Advisor accepts clients with the intent of maintaining the relationship for a long term basis. The Advisor seeks clients who can delegate the responsibility to the Advisor and who seek to build and maintain a long term relationship with an Advisor. The Advisor coordinates setting up an account or accounts at recommended broker/dealers who have a vendor relationship to the Advisor. The client is not obligated to use these brokers but it is suggested. In setting up this account, the client is signing a limited power of attorney which enables the Advisor to receive data from the broker/custodian, execute trades on behalf of the client, debit the Advisor’s fee from the account and process distributions to the client as long as the account source and destination have the same registration. The Advisor has in most cases discretion to trade the account without conferring in any way with the client. The Advisor will build an investment strategy based on the allocation across asset classes discussed above. The Advisor accomplishes this by selecting securities to purchase in the client account that include but are not limited to: stocks, bonds, exchange traded funds, open end mutual funds, closed end funds, options (covered calls on a limited basis), warrants, Treasury bills and notes, and structured products. The Advisor seeks to build portfolios with securities that have a high level of liquidity and trade in active markets. The Advisor implements the strategy in the client account/s and monitors the strategy periodically making changes as the Advisor so determines. The Advisor may also choose to delegate the management of an account to a sub‐ advisor who provides an area of expertise such as municipal bonds. If there is a separate fee for this service, the Client is notified and it generally deducted from the managed account by the sub‐Advisor. Changes to the strategy include:  Rebalancing in which the Advisor sells one or more securities and redistributes the proceeds amongst other securities, and  Purchase and sale of securities based upon research performed by The Advisor.
Changes to the strategy may be implemented based upon:  Material changes to the client financial objectives or time frame,  Research initiated by the Advisor  Tactical changes initiated by the Advisor triggered by other research or events, and  Trading opportunities spotted by the Advisor The Advisor has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, the Advisor will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the Client’s investment objective. Based upon these factors, there may be extended periods of time when the Advisor determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Advisor will be profitable or equal any specific performance level(s). Section C The Advisor recognizes that each client has his/her/their own financial goals and time horizons and therefore adapts the investment policy and asset allocation strategy to the individual needs of each client which are determined during the initial stage of the client relationship monitored

during the course of the relationship. As an example, one client may be a 60% equity allocation while another is a 40% equity allocation. The Advisor intends to own the same or similar securities (within the asset class portion of a client portfolio) to that of other clients of the Advisor with the exception of scale and percentage allocation to achieve consistency. There are exceptions namely:  Fixed income asset class bonds are not often available to be allocated across all accounts, and  Cannot always be purchased in enough quantity to fulfill all accounts,  Falcon Capital’s US Core sector has been designed to represent a large cap blend strategy, have a high correlation to a large cap benchmark and be scalable based upon portfolio size, as such and at the Advisor’s discretion: o Some portfolios may contain securities that individually have a high correlation to an equity benchmark, o Other portfolios may contain a basket of securities the sum of which have a high correlation to the same equity benchmark.
The Advisor for the most part does not allow clients to impose restrictions on investing or accept client suggestions on investments. There are however exceptions such as:  Clients who come to Falcon Capital with accounts containing extremely low cost basis stock/s,  Clients who come to Falcon Capital with bond positions in sufficiently small quantities that may not receive attractive prices upon sale,  Clients who come to Falcon Capital with an emotional attachment to a particular large holding that upon agreement may be coded as “non‐performance” and/or “non‐fee”, and  While we discourage client suggestions, we are certainly open to a discussion.
Section D The Advisor does not participate in wrap fee programs. Section E The Advisor as of December 31, 2023 had regulatory assets under management of $97,171,260 of which $ 89,940,131 was discretionary and $ 1,957,555 was non‐discretionary. The Advisor discourages non‐discretionary accounts and for the most part has not accepted any since 1996. Section F MISCELLANEOUS  Non‐Investment Consulting/Implementation Services. Although Advisor does not hold itself out as providing financial planning or related consulting services, to the extent specifically requested by a client, Advisor may provide limited consulting services regarding financial planning and separate financial planning studies such as college funding.
Neither Advisor, nor any of its representatives, serves as an attorney, accountant, or insurance agent, and no portion of Advisor’s services should be construed as same.  To the extent requested by a client, Advisor may recommend the services of other professionals for certain non‐investment implementation purposes (i.e. attorneys, accountants, insurance, etc.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Advisor. Please Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note: It remains the client’s responsibility to promptly notify Advisor if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Advisor’s previous recommendations and/or services.
 Client Obligations: In performing its services, Advisor shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify Advisor if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Advisor’s previous recommendations and/or services.
 Non‐Discretionary Service Limitations: Clients that determine to engage Advisor on a non‐discretionary investment advisory basis must be willing to accept that Advisor cannot effect any account transactions without obtaining prior verbal consent to any such transaction(s) from the client.
Thus, in the event of a market correction during which the client is unavailable, Advisor will be unable to effect any account transactions (as it would for its discretionary clients) without first obtaining the client’s verbal consent.
 Investment Risk: Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Advisor) will be profitable or equal any specific performance level(s).