Turner Capital Investments, LLC (“TCI" or “the firm”) is a registered investment adviser based in Austin, Texas. The firm has been providing investment advisory services since 2007. Michael Turner is the owner and managing member of TCI having experience in trading, investing, and risk management in the securities industry since 1997. How We Advise Clients in their Selection of which strategy to have their investment capital follow: Advisory services offered to TCI clients is predicated on specific strategies. Clients can select from the current list of strategies that best fit the client’s investment objectives. We review the client’s financial situation, goals, investment acumen and financial condition to assist the client in his/her selection of which of our strategies best fit the client’s financial goals and objectives. This includes taking into account various aspects of the client's personal circumstances, particularly the client's investment goals, time horizon, age and risk tolerance based on information and investment criteria provided to TCI by the client. The client risk profile that TCI has on file must support the level of downside risk associated with the TCI strategy that the client desires to follow. Our strategies are not diversified and we quantify the downside potential for risk and discuss that with the client to confirm the level of downside risk is within the tolerance the client can absorb. Each client will receive individualized investment treatment, as follows:
• Each client account can follow one or more of the TCI strategies.
• Each client account is managed according to the TCI strategies that the client has chosen to follow. The client can elect to move out of a strategy and into cash at any time, but it is important to understand that even when a client’s account is

in cash, there is no change in TCI’s management fee collection process.
• TCI obtains sufficient client information to be able to provide individualized investment advice to the client, but generally, this is limited to the client’s investment objectives and the TCI strategies that the client desires to follow;
• TCI is reasonably available to consult with the client;
• Each client is able to impose reasonable investment restrictions on the management of their account(s);
• Each client has on-line access to a monthly statement from the custodian of his or her account(s), with a description of all account activity; and
• Each client retains ownership of the securities and funds in the client’s account(s), e.g. the ability to withdraw securities, vote securities, among others. TCI client strategies are generally non-diversified since the strategy that the client has selected to follow is generally non-diversified. TCI takes a focused approach to asset allocation and we focus exclusively on stocks and ETFs, depending on the TCI strategy that the client desires to follow. We do not attempt to keep client accounts balanced within asset classes, bonds or mutual funds. Investors who seek a more diversified approach to investing in the stock market should not consider TCI for money management services. TCI serves as a sub-advisor to other RIAs. The services include providing buy/sell signals for the RIAs assets under management following one or more of TCI’s strategies. TCI conducts due diligence. Wrap Fee Programs We do not sponsor, manage, or participate in any wrap fee programs. Assets Under Management As of December 31, 2023, TCI had discretionary assets under management of approximately $106,876,898, and non-discretionary assets under management of approximately $0.