A. Description of the Advisory Firm B. Types of Advisory Services Compass Rose may direct clients to third-party investment advisers to manage a portion of all of client’s assets. Before selecting other advisers for clients, Compass Rose will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where Compass Rose is recommending the adviser to clients. 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. In offering financial planning, a conflict exists between the interests of the investment adviser and the interests of the client. The client is under no obligation to act upon the investment adviser’s recommendation, and, if the client elects to act on any of the recommendations, the client is under no obligation to affect the transaction through the investment adviser. Services Limited to Specific Types of Investments Compass Rose generally limits its investment advice to mutual funds, fixed income securities, insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds and non-U.S. securities. Compass Rose may use other securities as well to help diversify a portfolio when applicable. Compass Rose 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 Compass Rose on behalf of the client. Compass Rose 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 Compass Rose from properly servicing the client account, or if the restrictions would require Compass Rose to deviate from its standard suite of services, Compass Rose reserves the right to end the relationship. Compass

Rose participates in and sponsors a wrap fee program, which allows Compass Rose to manage client accounts for a single fee that includes both portfolio management services and brokerage costs. Compass Rose participates in wrap fee programs, which are investment programs where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. Compass Rose manages the investments in the wrap fee program, but does not manage those wrap fee C. Client Tailored Services and Client Imposed Restrictions D. Wrap Fee Programs accounts any differently than non-wrap fee accounts. Fees paid under the wrap fee program will be given to Compass Rose as a management fee. Compass Rose has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 99,962,048 $ 4,068,212 12/31/2022 Lower fees for comparable services may be available from other sources. For fee concerning the wrap fee program, please see the wrap fee brochure. Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $250,000 1.50% $250,001 - $1,000,000 1.00% $1,000,000 - And Up .80% The advisory fee is calculated using the value of the assets on the last business day of the prior billing period. These fees are non-negotiable, and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of Compass Rose's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. Selection of Other Advisers Fees Compass Rose may direct clients to third-party investment advisers. Compass Rose will be compensated via a fee share from the advisers to which it directs those clients. The fees shared are negotiable and will not exceed any limit imposed by any regulatory agency. The notice of termination requirement and payment of fees for third-party investment advisers will depend on the specific third-party adviser selected. E. Assets Under Management