4 A. Describe your advisory firm, how long you have been in business and identify primary owners. Beaumont Capital Management LLC ("BCM") is an asset manager based in Boston, Massachusetts. In 2009, Beaumont Capital Management was created as a division of Beaumont Financial Partners, LLC in order to deliver tactical, quantitatively driven investment strategies to financial professionals, institutions, and individuals. In late 2019, Beaumont Capital Management, LLC was spun off from Beaumont Financial Partners, forming a separate legal entity registered with the SEC effective as of the close of business on December 31, 2019. In January 2022, BCM was acquired by Algorithmic Investment Models, LLC (AIM). Both BCM and AIM are now owned by a holding company, Algorithmic Research + Trading LLC (ART) but continue to exist as separate legal entities and conduct business as usual. Beaumont Financial Partners, LLC organized in 1999, and its predecessor firm, Beaumont Trust Associates, started as a registered investment advisor in 1981. H & Co. Financial Services, Inc. (H & Co.) was also founded in the early 1980s and merged into Beaumont Financial Partners in October 2000. Beaumont Capital Management (BCM), powered by Algorithmic Investment Models (AIM), is an asset manager that provides Al-based, quantitative portfolio solutions designed to give investors attractive returns and a smoother ride by seeking maximum returns while managing volatility. Additionally, the firm has a suite of proprietary quantitative tools and machine learning capabilities that can be employed to develop custom research and investment solutions for RIAs and institutional investors. 4 B. Describe the types of advisory services offered. As an ETF strategist, BCM offers portfolios based on three quantitatively driven investment systems: Decathlon, Paradigm, and Sector Rotation. All three systems share a similar philosophy but are different in construct. The Decathlon system is based on machine learning and uses pattern recognition technology to find desirable, repeating patterns in the price histories of the ETFs in its pool. Paradigm seeks to avoid periods of high volatility as large drawdowns often occur during periods of high volatility, and the strategy is implemented using factor or "smart beta" ETFs. The Sector Rotation system uses ETFs focused on the sectors of the S&P 500, is trend following, and is based on the premise that both positive and negative trends, once identified, tend to persist for long periods. BCM primarily implements its strategies using Exchange Traded Funds (ETFs). BCM predominantly offers these strategies to investment professionals and institutions via four main channels of business: (1) Wrap fee programs, also known as Turnkey Asset Management Programs ("TAMPs") and/or Model Management Platforms (MMPs); (2) Sub-advisory contracts, including sub-advisor to a mutual fund; (3) Dual (client) contracts and direct business; and (4) Solicitor arrangements. The BCM strategies are offered in Separately Managed Account (SMA), Unified Managed Account (UMA), model manager and model delivery, and mutual fund formats. BCM relies on the "Source Advisor" (hereinafter defined as an investment advisor or Registered Representative who appoints BCM as an investment manager for one or more of their investment advisory clients' accounts) to successfully implement the know-your-client and suitability requirements under most TAMP, MMP, and Sub-Advisory arrangements, and BCM is not involved in these processes for these channels. For dual contract, direct, and solicitor arrangements, in addition to any Source Advisor's work, BCM will review each client's current financial situation and ascertain their: Investment objectives; Risk tolerance, investment time horizons, and income needs; Current investments and existing portfolio composition; and Other information pertaining to their unique situation and familial considerations. BCM will then work with each client to determine an overall asset allocation and help each client determine if a BCM portfolio might help them achieve their investment goals. BCM does not provide any other planning, tax, or advisory services. As noted above, BCM also acts as sub-advisor to a mutual fund: the Decathlon Market Neutral Fund. Prior to July of 2022, the fund was known as the BCM Decathlon Moderate Fund and followed a different investment strategy. Advisors Preferred, LLC is the investment adviser to the fund. Advisors Preferred, LLC is not affiliated with BCM. Investment Management Services BCM also provides investment advisory services to individual clients, primarily clients who are employees of the Firm,

and seeks to tailor its investment management services to meet the needs of its individual clients. In addition, BCM seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. BCM consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify BCM if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. In designing and implementing customized models and portfolio strategies, BCM can manage, on a discretionary or non-discretionary basis, a broad range of investment strategies and vehicles. BCM primarily allocates client assets among various investment managers mutual funds, exchange-traded funds (“ETFs”), closed-end funds (“CEFs”), individual equities, structured products, options, and debt securities in accordance with clients’ stated investment objectives, risk profile and financial condition. 4 C. Explain if, and how you tailor your advisory services to the individual needs of clients. Also, explain if clients may impose restrictions on securities or types of securities. As an ETF strategist, BCM does not tailor our strategies to investors' individual needs, nor do we allow restrictions to be placed on an account. Before agreeing to provide investment management services to sub-advisory, dual contract, and direct clients, BCM requires clients to affirm their understanding that the BCM strategies do not allow for tailoring to the individual needs of a specific client. To the extent that a client requires a more individualized service, BCM will not accept such business for lack of suitability. For TAMPs, MMPs, institutions, and solicitor opportunities, the Decathlon system is highly customizable and can be adapted to meet many mandates. Once these mandate strategy variants are set up, BCM cannot tailor to individual needs per the paragraph above. 4 D. If you participate in wrap fee programs by providing portfolio management services, (1) describe the differences, if any, between how you manage wrap fee accounts and how you manage other accounts, and (2) explain that you receive a portion of the wrap fee for your services. BCM is a participating manager on multiple wrap programs. In a wrap fee program, a client is charged a single, bundled, or "wrap" fee for investment advice, brokerage services, and other administrative services. BCM receives an annual management fee, typically paid quarterly, from the total wrap fee paid by the client. The total wrap fee and BCM's management fee will vary by strategy, custodian, and wrap program based on the circumstances and services provided. Accounts invested in BCM strategies via wrap programs are managed consistently with other clients in the same strategy. The investment decisions are based primarily on quantitatively researched, rules- based systems, and all clients invested in a given BCM strategy should have the same investment allocation and trade dates. In rare circumstances, due to actions of third parties, trades may not settle on the same date. Each wrap program and/or custodian has its own pre-determined trading schedules/trade cut-off times, account minimums, minimum fees as well as other terms and conditions and fees. BCM only receives a pre-determined management fee and receives no other compensation from a wrap program. Please see Item 5 for more information about fees and compensation. The wrap program sponsors, also known as Third Party Asset Management Programs (TAMPs) and/or Model Management Platforms (MMPs), are responsible for trade execution in most instances; therefore, the performance of two identical strategies may vary from one wrap program to another and from one custodian to another as trades are executed at different times. 4 E. If you manage client assets, disclose the amount of client assets you manage on a discretionary basis and the amount of client assets you manage on a non-discretionary basis. Disclose the date "as of" which you calculated the amounts. As of December 31, 2023, BCM had ~$2,202,911,265 in total assets under management and assets under advisement. The amount of discretionary assets as of December 31, 2023 was ~$155,335,629. This is the number that was reported as regulatory assets under management on Form ADV Part 1. BCM's assets under advisement totaled ~$2,047,575,636 as of December 31, 2023. This figure includes assets from model management programs and turnkey asset management programs.