CAPSTONE Investment Group, LLC (“CAPSTONE”), is a privately-owned investment advisor registered with the State of Washington since 2012. We are organized as a Limited Liability Corporation (“LLC”) in the State of Washington. Our Firm is dedicated to providing individuals and other types of clients with a wide array of investment advisory services. Sandra K. Drennon is the owner of CAPSTONE Investment Group, LLC Our Firm provides asset management and investment consulting services for many different types of clients to help meet their financial goals while remaining sensitive to individual risk tolerance and time horizons. As a fiduciary it is our duty to always act in the client’s best interest. This is accomplished in large part by knowing the client. Our Firm has established a service-oriented advisory practice with open lines of communication. Working with clients to understand their investment objectives while educating them about our process, facilitates the kind of working relationship we value. Financial Advisors who give investment advice on behalf of CAPSTONE have, at a minimum, demonstrated industry experience or its equivalent experience in business and/or have passed the FINRA (Formerly NASD) exam for Investment Adviser Financial Advisors (Series 65 or 66) and/or hold a professional designation, CFP (Certified Financial Planner) or equivalent. Types of Advisory Services Offered Financial Advisors provide investment management services, portfolio management and/or furnish investment advice. These services involve discretionary, daily oversight and selection of investment securities through fundamental and technical research, analyzing investment holdings to assist in managing client risk exposure while focusing on investor objectives. Portfolio Managers make daily decisions on a discretionary basis whereby our clients’ needs are maintained ahead of the firms’. Additionally, Financial Advisors may provide financial planning services, pension consulting, or offer selection of other financial services. Financial Advisors can tailor advisory services through a formal interview, risk tolerance questionnaire, or through other means such as a financial plan. Specific restrictions can be made for investing in certain types of securities by noting the same on the CAPSTONE Advisory Agreement or by notifying your Financial Advisor. Non-discretionary services are also available. CAPSTONE may provide ERISA fiduciary and non-fiduciary services to retirement plans and their participants when the client executes a Retirement Plan Advisory Agreement. In rendering fiduciary services, CAPSTONE is a “fiduciary” under the Employee Retirement Income Security Act of 1974 (“ERISA”) and the Investment Advisers Act of 1940. The following is a summary of the Services provided and more specific terms and conditions are contained in the Retirement Plan Advisory Agreement. ERISA Non-Discretionary Fiduciary Services: available include Investment Selection and Monitoring Services, Model Portfolios and Participant Advice, in providing these services CAPSTONE shall act as an ERISA Fiduciary.

The recipient of such advice retains the sole discretion as to whether to implement the advice and to initiate action to implement the advice. ERISA Discretionary Fiduciary Services available include Investment Selection and Monitoring Services, Model Portfolios and Qualified Default Investment Alternative. In providing ERISA Discretionary Fiduciary Services, CAPSTONE shall act as an ERISA Fiduciary and as an ERISA Section 3(38) Investment Manager. CAPSTONE shall retain final decision-making authority with regard to all ERISA Discretionary Fiduciary Services. The client retains the fiduciary responsibility to prudently select and monitor CAPSTONE in this regard. Financial Planning & Consulting: Our Firm provides a variety of standalone financial planning and consulting services to clients for the management of financial resources based upon an analysis of current situation, goals, and objectives. Financial planning services will typically involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, or Business and Personal Financial Planning. Written financial plans or financial consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. Implementation of the recommendations will be at the discretion of the client. Our firm provides clients with a summary of their financial situation, and observations for financial planning engagements. Financial consultations are not typically accompanied by a written summary of observations and recommendations, as the process is less formal than the planning service. Assuming that all the information and documents requested from the client are provided promptly, plans or consultations are typically completed within 6 months of the client signing a contract with our Firm. Tailoring of Advisory Services Our Firm offers individualized investment advice to our Comprehensive Portfolio Management clients. General investment advice will be offered to our Financial Planning & Consulting and Retirement Plan Consulting clients. Each Comprehensive Portfolio Management client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Participation in Wrap Fee Programs Our Firm does not offer or sponsor a wrap fee program. Regulatory Assets Under Management As of December 31, 2022, CAPSTONE Investment Group, LLC manages $108,736,888.00 in assets on a discretionary basis and $131,255.00 in assets on a non-discretionary basis.