Oars Capital (“Oars” or the “Firm”) provides comprehensive investment and wealth management services to individuals (“Clients”). The Firm was founded in 2012 by Marc Smith. Our primary function is managing investment portfolios for individual Clients, but we also provide a wide range of financial planning and wealth management services. These additional services are offered to Clients as part of their relationship with Oars and are not billed separately. We are compensated for all work we perform for Clients through our advisory fee, which is billed as a percentage of assets under management. Principal Marc Smith, the Firm’s Chief Executive Officer, Principal Member, Manager, and Chief Compliance Officer (“CCO”) is the founder of Oars. Marc founded Oars in 2012 after spending over two years with Hayek Kallen Investment Management, where he was a partner and portfolio manager. Marc has over 20 years of financial services experience in Charlottesville, VA, New York and Los Angeles. Prior to joining Hayek Kallen Investment Management, Marc was an analyst at a multi-strategy hedge-fund, where he invested in stocks, bonds and derivatives for institutional investors. His experience also includes working as a publishing Wall Street Analyst covering the retail/consumer products sectors for fixed income institutional investors as well as an investment banker on a variety of mergers & acquisitions and financing transactions. Overview of Services The Firm’s advisory services are tailored to the investment objectives of each Client. The Firm may set specific investment guidelines agreed upon by the Client. From time to time, Clients may impose certain restrictions on their account by discussing desired investment limitations with the Firm. Oars manages accounts using one of two strategies. Asset Allocation Model Oars’ investment philosophy is rooted in the concepts of asset allocation. We believe in creating a solid investment plan, tailored to each client, then executing that investment plan. This strategy uses a portfolio of Exchange-Trade Funds (ETFs) to gain exposure to a variety of asset class. ETFs are more tax-friendly than mutual funds and often have lower expense ratios. Lower fees on an ETF means higher returns for

you, the investor. We analyze ETFs on the expense ratio, total assets and investment approach. We are not bound by ETFs of a single issuer. Therefore, we look for the exposure to best provide Clients a portfolio that meets their goals and objectives. After creating your portfolio, we rebalance over time. Rebalancing is the process of selling asset classes that have outperformed and buying those that have underperformed. Effective asset allocation coupled with rebalancing is the optimal way to best help Clients achieve their financial goals. The overwhelming majority of the Adviser’s clients use this approach. Tactical Security Selection For Clients who prefer more active portfolio management, Oars offers a total portfolio approach based on a fundamental value investment philosophy. The philosophy is appropriate for many types of securities, although we primarily focus on stocks and bonds. This approach is achieved by combining a mix of stocks and bonds depending on each individual Client’s specific needs, objectives, risk tolerances, etc. The specific approach to each Client’s accounts is agreed upon at the beginning of the advisory relationship and updated as needed. Each account is managed individually, but there is frequently overlap in holdings between accounts. We discourage Client-driven restrictions on investment decisions, but we do occasionally agree to certain restrictions. Examples of restrictions we would agree to involve holding large, concentrated positions and agreeing not to own tobacco stocks in certain accounts. As of December 31, 2023, we had $329,109,903 of regulatory assets under management, all of which were managed on a discretionary basis. In addition to their respective wealth management accounts, certain of our Clients utilize our services to advise 529 and annuity accounts on their behalf. This activity is limited and does not comprise a material portion of the Firm’s overall business activity. Beyond providing investment management services to our Clients, Marc Smith occasionally provides consulting services to other registered investment advisors and pre-initial public offering private companies. At no point does he have direct investment control or trading authority over any accounts not managed by Oars.