Four Points Advisors, LLC (“Four Points”) is a Delaware limited liability company that was formed in March 2014, with its principal place of business located at 99 Park Avenue, 6th Floor, New York, New York 10016. Mr. Gene R. Murphy is Chief Compliance Officer of Four Points. Four Points currently offers investment advice, as well as, provides financial planning and consulting services to clients through separately managed accounts (the “Accounts”). Four Points specializes in discretionary portfolio management. Four Points does not limit its investment advice to any particular type of investments and may provide advice on a wide range of investments, including insurance, real estate and securities, which includes, but is not limited to, publicly-traded stocks, mutual funds, ETFs, fixed income securities (such as corporate bonds, treasuries, and other forms of indebtedness), options, and other securities specified in the written managed account agreement between a client and Four Points (the “Managed Account Agreement”). An Account will normally contain a relatively small number of investments and may not constitute a fully diversified or balanced investment portfolio that is suitable for all of a client’s assets. The Account will normally contain publicly traded stocks and a cash position (which may include, but is not limited to, treasuries and money market securities). Four Points generally has discretion to advise clients on any financial position they may hold, to the extent they so request. Financial planning contains a broad range of strategies which seek to meet the particular objectives of each client(s). Such plans are subject to the risk of regulatory changes in addition to risks associated with an Account. Four Points will tailor each Account to individual client needs by assessing their risk tolerance, liquidity and income needs and constructing an individual investment plan within these parameters. Four Points will outline the primary investment strategy with the client, describing how the strategy will benefit the client given their specific concerns, and explaining how the investment strategy can be altered in the future. Clients may opt out of a specific investment from their portfolio, require Four Points to obtain authorization prior to a transaction, and set specific cash amounts to be retained in the account. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. However, restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Four Points will work closely with a client to ensure the client understands each position of the account and how their liquidity needs will be met. Four Points will maintain a close relationship with each client in order to be attentive to alterations in investment risk tolerance and differences in life circumstances. All investment management activities and recommendations are provided directly by Four Points. Clients can engage Four Points to provide investment advisory services on

a fee-only basis. Advisory fees are payable quarterly, in advance, and are based on a percentage of the market value of assets under management for a particular client as further described in Item 5 – Fees and Compensation. Financial Planning Four Points may provide financial planning and consulting services to clients wishing to establish a comprehensive financial plan. At the current time Four Points does not charge an additional fee for this service but may choose to do so in the future. In that eventuality fees will be determined by the scope and complexity of the agreed upon services and fees will be negotiated and set forth in the Managed Account Agreement with the client. IRA Rollover Recommendation For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020- 02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. The Firm permits Employee personal trading, and maintains records as required under the Advisers Act. Our polices seek to prevent Employees from making competing transactions, trading against, or front- running client investments. The Firm may recommend that clients use the execution services offered by Four Points Capital Partners, LLC (“FPCP”), an affiliated broker/dealer registered with the SEC and the Financial Industry Regulatory Authority (“FINRA”) where the account may be held or transactions executed. FPCP will usually receive compensation when acting as a broker-dealer executing transactions for Four Points Advisors accounts. Wrap Fee Programs Four Points does not participate in wrap fee programs. Assets Under Management Four Points has approximately $30 million in assets under its management as of December 31, 2022. The Accounts will usually be managed on a discretionary basis.