Crew Capital Management, Ltd. (“CCM”) is a Registered Investment Adviser with the Securities and Exchange Commission (“SEC”). CCM was founded by Robert F. Jung, CFA, CPA, in January 2003. As of January 1, 2017, CCM was assigned 100% ownership to RFJ Holdings Inc. RFJ Holdings Inc. is a S Corporation owned by Robert F. Jung. CCM provides investment counsel and portfolio management on a “fee only” basis. CCM does not collect or receive commission revenue. CCM uses unaffiliated companies for custodial and other administrative services. CCM obtains investor profile data from clients to assist in the selection of suitable investments, asset allocations and portfolio management. Investment strategy is based on the client’s specific goals, risk tolerance, tax status and financial situation. Clients of CCM may restrict investment in certain securities or types of securities. CCM cannot control the restricted investment in funds it may utilize in the client’s portfolios. CCM also works with clients to implement an investment program in which client accounts are sub-managed by independent third-party money managers. More specifically, Crew will assist clients in determining the appropriate allocation of the clients’ invested assets among different asset classes, and in turn may recommend one or more third-party money managers who specialize in each of those asset classes. The third-party managers will be responsible for continuously monitoring the client account and making trades when necessary. CCM also provides financial planning services. CCM defines financial planning as Retirement Planning, Cash Flow Planning, Estate Planning, Income Risk Planning (Life and Disability Insurance) and Tax Planning. Financial Planning clients are charged an hourly or flat fee negotiated and agreed upon before the start of planning. As part of our investment advisory services to you, we may recommend that you withdraw the assets from your employer's retirement plan and roll the assets over to an individual retirement account ("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as set forth in the agreement

you executed with our firm. This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of: 1)) Leaving the funds in your employer's (former employer's) plan; 2) moving the funds to a new employer's retirement plan; 3) cashing out and taking a taxable distribution from the plan; and/or 4) rolling the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. Our recommendations may include any of them, depending on what we feel is in your best interest. We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also 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. As a fiduciary, we are required to document the reason(s) for why the recommendation we made is in your best interest. Beginning in November 2022 CCM established a new offering under the name Insurance Diligence Solutions (“IDS”). IDS provides third-party investment advisory diligence and oversight for private placement life insurance companies. As of December 31, 2023, CCM had discretionary assets under management in the amount of $183,099,087.05. CCM does not currently manage any non- discretionary assets.