St. Nicholas Private Asset Management, Inc. (St. Nicholas) was founded in 2004 in Jacksonville, Florida by Tim Cebulko, CFA/CFP and Allen Witham. We are currently under contract with Karen Bent Trust Services to provide administrative services only to our Lake County, FL clients. We added Robyn Cebulko as a Compliance/Tech Manager in April of 2021. Our goal is to provide a combination of investment management and client service at levels superior to our competition. Our methodology is built around the concepts of flexible investment management and back-to-basics client service. St. Nicholas’ Growth-at-a-Reasonable-Price (GARP) equity approach allows us to identify attractive purchase candidates regardless of the market’s current style preference. We utilize both growth and value companies and maintain exposure to all market cap levels. Our aim is to remain focused on the unique needs of our customers and to provide disciplined solutions, eschewing the “one-size-fits-all” approach some advisers take. We will strive to create a family-like atmosphere with our clients and service each of their specific needs individually. St. Nicholas is a privately-owned investment management company. We provide investment advisory services including equity and fixed income management. We also assist our clients in the setting and monitoring of investment objectives. We charge clients a percentage fee based on the amount of assets under management. Our client base is primarily individuals, but we also manage trusts, retirement accounts, and charitable accounts. As of December 31, 2023, our total assets under management were $130,066,330. The sole owners of St. Nicholas are Tim Cebulko, President/CCO, Allen Witham, Vice President and Robyn Cebulko, Compliance/Technology Manager. We have been operating

as a Registered Investment Advisor since September of 2004. Currently, St. Nicholas does not have any intermediate subsidiaries. IRA Rollover Recommendations For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02"), when applicable, we are providing the following acknowledgment to clients. When we provide investment advice to clients regarding their retirement plan account or individual retirement account, we are a fiduciary 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 client interests. We operate under an exemption that requires we act in the clients’ best interest and not put our or our employees’ interest ahead of the clients. Under this exemption, we must:
• meet a professional standard of care when making investment recommendations (give prudent advice),
• never put our or our employees’ financial interests ahead of the clients when making recommendations (give loyal advice),
• avoid making misleading statements about conflicts of interest, fees, and investments,
• follow policies and procedures designed to ensure that our and our employees give advice that is in the clients’ best interest,
• charge no more than is reasonable for services, and
• give the clients basic information about conflicts of interest. We benefit financially from the rollover of the clients’ 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 our and our employees believe it is in the clients’ best interest.