A. Description of Firm and Principal Owners Spectrum Capital Investment Group, Inc. (“Spectrum”), a Securities and Exchange Commission (“SEC”) Registered Investment Adviser, provides customized investment management services to individuals, businesses, pensions, trusts, and/or estates. Spectrum has been in business since August of 2005 and Mr. Benjamin R. Putman has been the sole owner for this period of time. B. Types of Advisory Services Offered 1. Investment Management Services At the onset of the client relationship, Spectrum typically collects information pertaining to each client’s investment objectives, risk tolerance, investment guidelines, time horizons and other important and necessary information. Should anything in the Client's Profile or Investment Policy Statement change due to various circumstances, it is the Client’s responsibility to notify Spectrum in writing as soon as possible. Spectrum does not assume responsibility for the accuracy of the information provided by the client and is not obligated to verify any information received from the client or from any of the client’s other professionals (e.g., attorney, accountant, etc.). Spectrum generally will meet with all clients no less than annually to review the client’s investment goals and current advisory portfolios. Spectrum provides discretionary investment management services on a continuous basis. The investment advice we provide is customizable, with each client’s portfolio separately managed based upon the needs, objectives, and other financial goals of our clients. Such advice will typically involve providing a variety of services and include investment buy/sell recommendations, asset allocation, recommendation of independent advisers, and the selection of mutual funds and/or securities for the client’s portfolio. Spectrum utilizes various instruments, including stocks, bonds, REITs, exchange traded funds and mutual funds to achieve asset allocation while constructing an investment portfolio based upon the client's investment objectives. Upon the client's request, Spectrum may continue to hold individual securities that the client brought into the portfolio at the account’s inception. 2. Financial Planning Services Spectrum offers financial planning services to non-advisory clients. Hourly fee basis or fixed fee plans are available for Client preference. Generally, a financial planning agreement will be signed before services commence. Financial planning consists of assisting Client in defining personal financial planning goals and objectives in applicable areas which include, but are not limited to: cash flow projections, budgeting, business planning, divorce planning, retirement planning, tax planning, estate planning, investment planning, children’s education, insurance coverage review, long- term care insurance review, investment account aggregation advice and others. Client may not wish to engage in the financial planning portion of our service but these services are available to you on an hourly or flat-fee basis. If a conflict of interest exists between the interest of Spectrum and the interest of Client, Client is under no obligation to act upon Spectrum’s recommendation. If Client elects to act on any of the recommendations, Client is not obligated to affect the transaction through Spectrum. 3. Private Placements Spectrum may provide investment advice and due diligence regarding certain privately-issued securities for accredited investors. Spectrum will collect all available information- marketing materials, auditing reports, balance sheets, offering memorandum, subscription agreement, review historical records and assess opportunities and risk for existing and future investments. Spectrum will make a best effort evaluation based on available and pertinent information provided by the private placement to properly advise client. Because investment in these types of entities may involve certain additional degrees of risk, they will only be recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. 4. Use of Third Party Advisers (“TPAs”) Dependent upon the client’s needs or objectives, Spectrum may recommend the services of an independent Third- Party Adviser

("TPA") to manage a portion of their portfolio. Typically, this involves the selection of certain wrap- fee programs, or money managers which may enter into a separate agreement with Spectrum. Spectrum's recommendations regarding the suitability of a TPA and its investment style is based on, but not limited to, the client’s financial needs, long-term goals, and investment objectives. Upon selection of a TPA, Spectrum will conduct periodic due diligence ensure that the TPA's performance, portfolio strategies and management remain aligned to the client’s overall investment goals and objectives. Spectrum will retain discretionary authority to hire and fire TPAs and reallocate the client’s assets to other TPAs, where such action is deemed to be in the best interest of the client. Clients may be required to sign a separate investment management agreement directly with the TPA(s) selected, in addition to the advisory agreement signed with Spectrum. The client, Spectrum or the TPA, in accordance with the provisions of those agreements, may terminate the advisory relationship at any time. If the TPA is compensated in advance, the client will typically receive a pro-rata refund of any prepaid advisory fees upon termination. Should Spectrum select a TPA to manage a portion of the client’s portfolio, Spectrum will instruct the TPA to deliver a copy of the TPA’s Form ADV Part 2A (or other similar Client Brochure) to the client at the time of appointing the TPA. Spectrum will periodically review the Form ADV Part 2A delivery process of all TPAs as part of its on-going due diligence efforts. 5. Pension Consulting Services Spectrum offers pension-consulting services to qualified and non-qualified retirement and deferred compensation plans. In general, these services may include the review and/or development of an Investment Policy Statement (“IPS”); analysis, review and recommendation of investment selections; asset allocation advice; communication and education services where Spectrum assists the plan sponsor in providing meaningful information regarding the retirement plan to its participants; investment performance monitoring and/or ongoing consulting. The plan fiduciary is free to seek independent advice about the appropriateness of any recommended services for the plan. C. Client Agreements and Disclosures Each client is required to enter into a written agreement with Spectrum setting forth the terms and conditions under which the Firm shall render its services (the “Agreement”). In accordance with applicable laws and regulations, Spectrum will provide its disclosure brochure (ADV Part 2A), brochure supplement (ADV Part 2B) and most recent Privacy Notice to each client prior to or contemporaneously with the execution of the Agreement. The Agreement between Spectrum and the Client will continue in effect until terminated by either party pursuant to the terms of the Agreement. Spectrum’s fees (as discussed below) shall be prorated through the date of termination and any remaining balance shall be charged or refunded to the client, as appropriate, in a timely manner. Neither Spectrum nor the client may assign the Agreement without the consent of the other party. Transactions that do not result in a change of actual control or management of Spectrum shall not be considered an assignment. As further discussed in Item 15 below, client’s assets will be custodied with a qualified custodian. All custodial and execution fees assessed for client’s assets remain the sole responsibility of client. D. Participation in Wrap Programs Spectrum does not serve as the sponsor and/or sub-adviser to any wrap programs at this time. E. Amount of Client Assets Managed As of March 13, 2023, Spectrum manages $134,300,000 on a discretionary basis and $38,700,000 on a non- discretionary basis. Spectrum Capital Investment Group Inc. also provides investment consultant services to participants in defined- contribution and defined-benefit retirement plans whose employers (plan sponsors) have contracted with Spectrum to provide such services to them. Spectrum utilizes third party plan administrators for retirement plan design and compliance and may use TPA for the investment management and record-keeping services.