A. Description of Firm Thompson Capital Management, LLC (the "TCM" or the "Firm") is an Illinois-based federally covered advisory firm that provides investment advisory, sub-advisory and other services. TCM is a limited liability company having been formed in the State of Illinois in 2019 is currently operated by Mike and Matt Thompson. B. Types of Advisory Services Offered 1. Investment Management Services TCM manages investment advisory accounts for individual Clients (such separately managed accounts hereinafter referred to as ("SMAs"), collectively referred to herein as "Clients") through model portfolios. We regularly provide advice to Clients regarding equity securities, convertible securities, debt instruments, options, leveraged and inverse ETFs, private securities, margin, and other investments and instruments. Our advice includes the use of leverage in certain model portfolios. TCM primarily provides investment management where Client portfolios are managed, on a continuous basis, through our strategies, Legacy Navigator, Alpha Seeker, Hedged Yield, Tactical Beta, Tactical Q, EAFE Smart Index, EEM Smart Index, and Hedged Disruptor (collectively referred to as the "Investment Strategies"), in accordance with a Client's stated investment objectives and goals. TCM investment management strategies focus on using historically strong, negative correlation of VIX exposures to offset equity risk across three broad categories: Category Description Strategies Risk-Managed Indexing Equity exposures with a tactical risk-management strategy that uses VIX-linked exchange traded products (“ETPs”) to reduce portfolio exposure during periods of increased volatility. EAFE Smart Index Emerging Markets Smart Index Tactical Beta Tactical Q Hedged Yield Hedged Disruptor Alternatives Seek positive annual return with low correlation to stocks and bonds using a tactical trading approach with long and short S&P 500 and VIX exposures. Alpha Seeker Modeled Strategies Combine two or more portfolios in the same account. Legacy Navigator TCM holds a limited power of attorney to act on a discretionary basis with Client funds. The Firm's discretionary authority is subject to conditions or restrictions imposed by a Client. Our Clients impose reasonable restrictions on their accounts with respect to (1) the specific types of investments or asset classes that we will or will not purchase for their account; (2) the nature of the issuers of investments that we will or will not purchase for their account; or (3) the risk profile of instruments we will or will not purchase for their account, or the risk profile of the account as a whole. TCM does not maintain possession or custody of the funds or securities of any Client. Client funds will typically be deposited in either a brokerage firm or qualified custodian account. With Client consent, TCM will typically cause fees to be paid out of separately managed accounts by the Client's custodian. 2. Sub-Advisory

Services TCM participates as a sub-advisor under other firms' advisory programs. When engaged in a sub- advisory capacity, TCM charges the investment adviser for its sub-advisory services. As a sub-adviser, TCM has discretionary authority for the ongoing management of assets. The unaffiliated investment advisers are responsible for both the initial and ongoing day-to-day relationship with the underlying Client, including initial and ongoing determination of the Client's suitability for TCM's investment strategies. 3. Financial Planning Services TCM provides financial planning services where an adviser works with a Client to review their current financial position, stated goals, and objectives. TCM will make recommendations on how a Client can manage their financial resources based on an analysis of their individual needs. Financial planning services can include a cash flow analysis, college and education planning, and debt analysis. Recommendations may be in the form of a written financial plan, or a verbal consultation based on the type of engagement. The Client is under no obligation to act upon the adviser's recommendations. If the Client elects to act on any of our recommendations, they are Client under no obligation to affect their transactions through our Firm. Financial planning services do not include investment implementation or ongoing investment supervision, monitoring, or reporting services. Investment management services may be obtained from TCM through a separate investment management agreement or through a separate professional investment adviser of the Client's choosing. Clients should contact their tax and/or legal adviser for personal tax and/or legal advice. C. Client Agreements and Disclosures Each Client is required to enter into a written agreement with TCM setting forth the terms and conditions under which the Firm shall render its services (the "Agreement"). In accordance with applicable laws and regulations, TCM 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 TCM and the Client will continue in effect until terminated by either party pursuant to the terms of the Agreement. TCM'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 TCM 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 TCM shall not be considered an assignment. As further discussed in Item 15 below, Clients' 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. Amount of Client Assets Managed TCM has $ 193,724,389 in discretionary assets under management as of December 31,2023.