A. Description of the Advisory Firm Connecticut Capital Management Group, LLC (hereinafter “CCMGL”) is a Limited Liability Company organized in the State of Connecticut. The firm was formed in May 1998, and the principal owner and Chief Compliance Officer is Brian Parke. B. Types of Advisory Services Portfolio Management Services (Direct) CCMGL offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. CCMGL creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring CCMGL evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. CCMGL seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of CCMGL’s economic, investment or other financial interests. To meet its fiduciary obligations, CCMGL attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, CCMGL’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is CCMGL’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Portfolio Management Services (via Selection of Other Advisers) CCMGL may offer investment advisory services through use of third-party money managers (“Outside Managers” and “Sub-Advisers”) for portfolio management services. In doing so, CCMGL assists clients in selecting an appropriate allocation model, completing the investor profile questionnaire, interacting with the Outside Manager and reviewing the Outside Manager. CCMGL will meet with the client on a periodic basis to discuss changes in their personal or financial situation, suitability, and any new or revised restrictions to be applied to the account. Before selecting other advisers for clients, CCMGL will always ensure those other advisers are properly licensed or registered as an investment adviser. CCMGL conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. CCMGL then makes investments with a third- party investment adviser by referring the client to the third-party adviser. CCMGL will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Specifically, CCMGL will direct clients to a third party and its affiliates (collectively, “Independent Manager”), which include Independent Manager’s affiliated investment advisory firm (the “Independent Manager Affiliate”) and broker-dealer. Independent Manager has developed a standard managed account solutions (“MAS”), which program includes Independent Manager ’s distribution focused strategies, an integrated managed account solutions providing a tax overlay service (“Tax Management”) and a Goals Based Investing managed account solutions, consisting of MAS and Tax Management portfolios invested in accordance with Independent Manager ’s goals- based investment solutions and, may, in the future, develop additional managed account solutions (collectively, the “Managed Account Solutions”). Under this program, Independent Manager Affiliate acts a co-investment advisor to the client, along with the CCMGL, pursuant to a tri-party investment management agreement executed among Independent Manager Affiliate, CCMGL and each client investing assets into the Managed Account Solutions (the “Tri-party Agreement”). For each Managed Account Solutions, Independent Manager Affiliate is responsible for developing managed account portfolios designed to be invested in accordance with a stated investment objective (the “Managed Account Portfolios”). For each Managed Account Portfolio, other than the Managed Account Portfolios implementing distribution- focused strategies (the “DFS Portfolios”), Independent Manager Affiliate is solely responsible for screening, reviewing and selecting the various money managers and/or individual mutual funds and other assets available for selection by CCMGL and their clients designed to meet the specific Managed Account Portfolio’s stated investment objective or goal. For each DFS Portfolio, Independent Manager Affiliate is responsible for selecting the Independent Manager’s funds and/or other assets underlying each DFS Portfolio and actively managing each client’s account invested in a DFS Portfolio in accordance with the portfolio’s investment objectives. Pursuant to the Managed Account Solutions, Independent Manager Affiliate will provide to CCMGL, and its investment

adviser representatives of CCMGL the following services:
• Make available to CCMGL and its investment adviser representatives of CCMGL Managed Account Portfolios developed solely by Independent Manager Affiliate and designed to achieve specific investment objectives or goals, and, pursuant to which the clients, with recommendations from investment adviser representatives of CCMGL, will select from a list of available money managers (which may include Independent Manager Affiliate), Independent Manager mutual funds, and/or other assets and, in the case of DFS Managed Account Portfolios, investment strategies managed solely by Independent Manager Affiliate, and which Independent Manager Affiliate has determined: (i) as to available money managers, will invest in accordance with the Managed Account Portfolio’s stated investment objective or goal; and (ii) as to available individual mutual funds and other assets, are intended to help achieve the specific Managed Account Portfolio’s stated investment objectives or goals.
• In its sole discretion, rebalance the model asset allocation mix of the Managed Account Portfolios (including adding, removing or otherwise changing money managers available to manage assets within a portfolio, or the mutual funds or other assets available), as necessary to remain consistent with the model Managed Account Portfolio’s investment objectives and otherwise be fully responsible for determining that the Managed Account Portfolios remain invested consistent with their stated investment objective or goal and will notify CCMGL of any money manager change.
• Through a proprietary web-based portfolio modeling system, recommend to CCMGL one or more Managed Account Portfolios that may meet a client’s investment objective(s), based solely on that client’s financial and other information provided to Independent Manager by CCMGL.
• In its role as co-advisor to clients in the Managed Account Solutions, manage each Managed Account Portfolio, including, without limitation, (i) monitoring the performance of each selected money manager, in accordance with the portfolio’s stated investment objective or goal and in accordance with the terms of the Tri- party Agreement and (ii) for client accounts invested in DFS Portfolios, be solely responsible for selecting, managing and rebalancing the Independent Manager funds or other assets included in the client accounts necessary for such accounts to be and remain invested in accordance with the applicable DFS Portfolio’s investment objective, as selected by clients with the assistance of investment adviser representatives of CCMGL. Pension Consulting Services CCMGL offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to:
• identifying investment objectives and restrictions
• providing guidance on various assets classes and investment options
• recommending money managers to manage plan assets in ways designed to achieve objectives
• monitoring performance of money managers and investment options and making recommendations for changes
• recommending other service providers, such as custodians, administrators and broker-dealers
• creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Services Limited to Specific Types of Investments CCMGL generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements. CCMGL may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions CCMGL will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by CCMGL on behalf of the client. CCMGL may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent CCMGL from properly servicing the client account, or if the restrictions would require CCMGL to deviate from its standard suite of services, CCMGL reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. CCMGL does not participate in wrap fee programs. E. Assets Under Management CCMGL has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 194,140,297 $ 9,578,063 December 2023