A. Business Commencement Date Phraction was organized in August of 2018 to offer investment management services. B. Ownership Mapfair LLC owns a majority membership interest in Phraction. Mr. Jason Stollman is the sole member and manager of Mapfair LLC. C. Services DISCRETIONARY ACCOUNTS. We provide personalized discretionary investment management services. Clients are asked to provide us with information with respect to their financial and investment profile, including current financial holdings, investment preferences and objectives, risk tolerance, present and long-term liquidity needs, investment time horizon(s), wealth planning needs and objectives, insurance coverage requirements, and tax status. We will also inquire as to the restrictions, if any, the client wishes to impose on the management of the advisory account. From the information supplied by the client, we formulate and pursue a customized asset allocation and investment strategy that we believe is suitable and will help the client achieve the stated investment objectives. We actively manage the discretionary account on an ongoing basis in accordance with the account’s objective(s) and in consideration of the client’s investment time frame and risk tolerance. Account monitoring is performed on a continual basis. See Item 8A for information about our analysis method. See Item 13 for additional information about account monitoring and reviews. As dictated by the client, we will also provide advisory services regarding family governance, estate planning, and intergenerational wealth transfer. We do not provide legal or tax advice. Clients are encouraged to consult with their legal or tax attorneys or advisers regarding legal and tax matters. LIMITED DISCRETIONARY ACCOUNTS. We also offer limited-discretionary advisory services tailored to the client’s needs. As with the discretionary accounts, clients are asked to provide us with information regarding their financial profile (as detailed above) and any restrictions the client wishes to impose on the management of the accounts. For limited-discretionary accounts, we will recommend and investment strategy, allocation mix, or changes to the client’s existing portfolio that we believe is suitable for that client. Account monitoring is performed on a continual basis. See ITEM 13 for additional information about account monitoring and reviews. On an ongoing basis, we made buy/sell recommendations to the client as appropriate, based on the clients financial and investment profile and investment objectives. Where the client approves of a recommendation, we will arrange to the effect the recommended transaction(s) in the clients account using a limited power of attorney granted to us by the client. We will prove advice regarding family governance, estate planning, and intergenerational wealth transfer as requested by the client. We do not provide legal or tax advice. Clients are encouraged to consult with their legal or tax attorneys or advisers regarding legal and tax matters. MANAGER SELECTION. We offer ongoing portfolio manager evaluation and selection services where we obtain the authority from the client to retain and terminate the services of third-party portfolio managers on a discretionary basis and reallocate assets between or among portfolio managers. At the inception of the advisory relationship, we perform a comprehensive review of the portfolio managers managing the client assets. We evaluate, among other things, each manager’s investment style and style consistency, tenure and expertise, risk philosophy, and track record in each specific investment strategy followed. We routinely communicate with the portfolio managers regarding the client’s account. We undertake a formal evaluation of the manager (or manager’s team) at least quarterly, or more often if significant economic events or market volatility dictates. Upon the conclusion of each review, we determine whether to terminate the services of the portfolio manager(s), retain new portfolio manager(s),

and/or reallocate assets among managers. We immediately communicate to the client when a change is determined and prepare the necessary documents to effect the change. CONSOLIDATED REPORTS. We provide consolidated report services to clients upon request. Although we do not charge a separate fee for this service, where the client pays a fixed fee for the advisory services, the determination of the fixed fee to be charged will be based, in part, upon the number of accounts that will be included in the consolidated reports as well as the work involved in obtaining valuations for the assets. The client determines which assets will be included in the consolidated reports and can request that we include information about accounts or assets for which we do not provide investment management services. The consolidated reports are provided on intervals mutually agreed to by the client and us. SUB-ADVISORY SERVICES. We provide advice and investment recommendation services to certain other investment advisors in connection with the management of their client portfolios. The investment advisor furnishes to us their clients’ information such as investment objectives, risk tolerances, time horizons, liquidity needs, investment restrictions and management expectations. If the sub-advisory arrangement is discretionary in nature, we manage their clients’ assets directly consistent with the client profiles. Otherwise, we provide to the investment advisor advice and recommendations regarding the investments and investment strategies consistent with the information provided. For non-discretionary arrangements, the investment advisor determines whether to implement our advice and recommendations and we do not have the authority to place orders for the account assets or otherwise manage the accounts directly. CONSULTING. We provide non-discretionary services to one or more entities, which services may include (1) periodically providing research and/or reports concerning general economic conditions and/or types of securities, (2) making investment buy/sell suggestions or recommendations, (3) suggesting asset allocation mixes, and/or (4) non-discretionary portfolio management advice regarding the selection of investment securities and/or investment vehicles and the quantities or amounts of securities or other interests to be purchased, leveraged, transferred, exchanged, traded and/or sold by certain customers of the entity consistent with and based on our analyses of the investment requirements and objectives adopted by the customer and communicated to us by the entity/individual (either directly or through a reporting system to which the entity gives us access). We also provide similar non-discretionary services for individual (natural person) accounts which may include advice regarding family governance, estate/financial planning, and intergenerational wealth transfer as requested by the client. The client is free to implement or disregard in whole or in part any recommendations, advice or suggestions we make. We do not arrange for or effect any transactions for any of the entity’s accounts or its customers’ accounts or for the individual client. INVESTMENT PRODUCT TYPES. Generally, the Firm’s investment advice is confined to the following universe of securities and products: ▪ Exchange listed securities; ▪ Securities traded over-the-counter; ▪ Securities issued by foreign issuers, including foreign sovereign debt instruments; ▪ Preferred stock; ▪ Emerging market securities; ▪ Corporate debt securities; ▪ U.S. government securities; ▪ Open-end mutual funds (foreign and domestic); ▪ Closed-end funds; ▪ Exchange-traded funds; ▪ Private equity funds and hedge funds; ▪ Options contracts; ▪ Futures contracts; ▪ Interests in REITs; and ▪ Interests in private placements. D. Wrap Fee Program We do not participate in any wrap fee programs. E. Assets Under Management As of December 2023, we were managing approximately US $ 450,985,988.00 on a discretionary basis.