Saiph Capital offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to Saiph Capital rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Saiph Capital setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Saiph Capital filed for registration as an investment adviser in December 2020 and is owned by Paul Brian Saxton as of February 12, 2021. As of February 2, 2024, the firm has $640,482,353 in assets under management, $297,028,858 of which is managed on a discretionary basis and $343,453,495 of which is managed on a non-discretionary basis. While this brochure generally describes the business of Saiph Capital, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or other persons who provide investment advice on Saiph Capital’s behalf and are subject to the Firm’s supervision or control. Financial Planning and Consulting Services Saiph Capital offers clients a broad range of financial planning and consulting services. The services include, but are not limited to: retirement planning, education planning, estate planning, business planning and cash flow analysis. These services are generally rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, Saiph Capital is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Saiph Capital recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Saiph Capital or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Saiph Capital under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Saiph Capital’s recommendations and/or services. Page | 5 © MarketCounsel 2024 Investment and Wealth Management Services Saiph Capital provides clients with wealth management services which include a broad range of financial planning and consulting services as well as discretionary and/or non-discretionary management of investment portfolios. Saiph Capital primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), and individual debt and equity securities in accordance with their stated investment objectives. Where appropriate,

the Firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage Saiph Capital to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Saiph Capital directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. Saiph Capital tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Saiph Capital 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 Saiph Capital if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if Saiph Capital determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Retirement Plan Consulting Services Saiph Capital provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Saiph Capital offers these services for 401(k), profit sharing, non-qualified deferred compensation and retirement plans that are subject to the Employee Retirement Income Security Act of 1974 (“ERISA”) and other employee retirement plans not subject to ERISA. Saiph Capital will serve as a “fiduciary” within the meaning of Section 3(21) of ERISA and provide non- discretionary advice with respect to the assets and/or accounts in the Plan. Page | 6 © MarketCounsel 2024 Each engagement is individually negotiated and customized, and includes any or all of the following services:
• Plan Design and Strategy
• Plan Review and Evaluation
• Executive Planning & Benefits
• Investment Selection
• Plan Fee and Cost Analysis
• Plan Committee Consultation
• Fiduciary and Compliance
• Participant Education As disclosed in the Advisory Agreement, certain of the foregoing services are provided by Saiph Capital as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of Saiph Capital’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement.