A. OWNERSHIP/ADVISORY HISTORY Bloomsbury Asset Management LLP (“We”) (Bloomsbury Asset Management) (“Bloomsbury”) is a Montana based Limited Liability Partnership registered in July 2018. Jag Balfour is the Managing Partner and majority owner of Bloomsbury Asset Management LLP. Additional information about the Bloomsbury’s majority owner and Managing Partner can be found in our Supplement Brochure which can be obtained on request. B. ADVISORY SERVICES OFFERED We offer both discretionary investment management services and financial planning services. Before we enter into an advisor-client relationship, we may offer a complimentary general consultation to determine a prospective client’s needs and discuss services avai lable that meet those needs. Only after a prospective client has had time to review our solutions/services can they determine whether a relationship might benefit them. Investment advisory services begin only after we and the client formalize the relationship with a properly executed agreement setting forth the terms and conditions under which we will provide our services. i. FINANCIAL PLANNING We offer clients limited financial planning services to evaluate their financial situations, goals, including risk tolerance, and time horizon, upon request. Through a series of personal exploratory interviews and the use of questionnaires, the firm will collect pertinent data, identify goals, objectives, financial problems, and potential solutions. This initial meeting will determine the extent to which financial planning and investment management is necessary. We will prepare and present specific recommendations and implement those recommendations, as agreed upon with the client. As a result of these actions, our advice may be provided on, (but is not limited to): financial and cash flow management, asset allocation and diversification planning, estate planning, strategic income tax planning, retirement planning, educational funding, goal setting, a review of insurance policies with risk management, review of employer sponsored retirement plan options or other needs as identified by the client and the firm, all potentially provided with recommendations. We may offer comprehensive planning services or the client may desire advice on certain planning components; the firm can tailor services as desired by the client. At the conclusion of the financial planning service, the firm may present the client with a written financial plan. This financial planning service involves rendering a financial consultation for you based upon an analysis of the documents and information that you provide us.

We may recommend that you utilize various financial products, such as insurance or other advisory services, to implement our recommendations and to achieve your goals. You are not obligated to follow our recommendations. We also may recommend that you work with other professionals, such as attorneys or accountants. Additionally Bloomsbury Asset Management LLP takes no responsibility for the outcome of our advice related to employer sponsored retirement plans in part due to the limited options available within these types of plans. ii. PORTFOLIO MANAGEMENT We provide portfolio management services to interested clients on a client specific basis, based upon your unique facts and circumstances. Although we manage your accounts based on your individual needs, we construct client portfolios in accordance with our model asset allocation strategies, which are adjusted for each client’s risk profile. The model asset allocation strategies range from aggressive growth to capital preservation. Upon selecting your risk tolerance profile, allocations are made to each of the models depending upon what is appropriate for you. We rely on the client to accurately specify their own risk tolerance to be able to fit their needs to the appropriate model portfolio. All of the model strategies include some combination of individual stocks, mutual funds, exchange traded funds, alternative investments, options, individual bonds, certificates of deposit, and may potentially include other investment products. We develop these models based upon our proprietary research on markets and market conditions as well as perceived value in selecting securities. Please see Item 8 for additional details. We periodically review your accounts on an ongoing basis (by monitoring our models) to ensure that risk levels stay within the parameters established by your risk tolerance. We rebalance your portfolios as necessary. More or less frequent rebalancing may be required depending on macroeconomic, market or sector factors, as well as changes in your personal or family circumstances. C. TAILORED SERVICES We tailor all of our services to the clients stated goals, needs and objectives. For our portfolio management service clients, we allow them to impose restrictions on investment in certain securities or types of securities. All restrictions must be presented to us in writing. D. WRAP PROGRAM We do not offer a wrap fee program. E. CLIENT ASSETS MANAGED As of the date of this brochure the worth of the securities portfolio managed by the firm is approximately $4,300,000.