Advisory Firm and Principals. Brighton Securities Capital Management Inc. ("Brighton Securities Capital Management," "we," "our," or "us") is New York corporation established on April 15, 2021 offering fee- only investment advisory and financial planning firm. Brighton Securities Capital Management is a subsidiary of Brighton Securities Holdings Inc. Advisory Services Offered. We may offer all or any combination of the investment advisory and financial planning services described below. Investment Advisory Services. We provide clients with investment management services with respect to their investment accounts. Our clients are primarily individuals and their families, but we also offer services to trustees, executors, qualified retirement plans, and business entities. We construct portfolios based on our assessment of a client's risk profile, investment objective(s), time horizon, withdrawal or spending needs, account restrictions (if any), and overall financial situation. Portfolios generally consist of mutual funds (either no-load or load waived, sometimes referred to as "load-at-NAV") and exchange-traded funds (ETFs), with a heavy emphasis on index-tracking funds. Some of portfolios may utilize individual equity or fixed income securities, and individual client accounts may hold individual securities. The client may place reasonable restrictions on the types of investments to be held in the portfolio, provided that such restrictions are agreed upon in writing. Financial Planning Services. Other financial planning services may be provided based on a client's needs and objectives and the level of services desired. These services may be provided on a one-time or on- going basis. Depending

on the particular circumstances, financial planning services may be broad in nature or limited to specific issues or concerns. For example, a broad financial analysis could include a review of a client's overall financial condition, income and tax status, personal and business assets, insurance needs, risk profile, retirement planning, estate planning, and other factors unique to a client's particular circumstances. We may also offer advice regarding the rearrangement of cash flow in order to fund certain long-term objectives such as retirement planning. We may identify legal or tax issues a client needs to address and coordinate with other professionals to ensure that these issues are properly addressed. We do not, however, render legal, tax or accounting advice or prepare any legal documents for clients. We may refer clients to an accountant or attorney for development of tax or estate plans. The client personal attorney is solely responsible for providing legal advice and documents. The client's personal tax adviser or accountant is solely responsible for any tax or accounting advice. Financial planning services may also take the form of investment advice in situations where investment accounts are not held with a custodian with whom we have a relationship and, therefore, where we do not provide ongoing investment management. For example, these services may include advice regarding asset allocation, investment portfolio construction, investment selection, performance review, or other services as agreed upon. Assets Under Management. As of on or about December 31, 2023, Brighton Securities Capital Management managed approximately $194,956,017.22 on a discretionary basis.