A. Description of the Advisory Firm Aragon Capital LLC is a Limited Liability Company organized in the state of Florida. The firm was formed in February of 2013, and the principal owners are Ricardo Franco Nieto and Alberto Chocron. B. Types of Advisory Services Aragon Capital LLC (hereinafter “AC”) offers the following services to advisory clients: Investment Supervisory Services AC offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. AC creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring AC evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Selection of Other Advisers In certain cases, where appropriate, Aragon Capital LLC ("we") may recommend that certain clients engage Regal Investment Advisors, LLC dba "Lionshare" to provide investment advice on a sub-advisory basis through their investment platform. We will assist clients with selecting and implementing the appropriate investments, asset allocation strategy and will monitor the performance and suitability of these Lionshare strategies. We will contact clients from time to time to review their financial situation and objectives; communicate information to Lionshare as/when warranted; and assist the client in understanding and evaluating the services provided by Lionshare. Clients will be expected to notify us of any changes in their financial situation, investment objectives, or account restrictions that could affect their financial situation. For the clients that engage Lionshare for the investment management of their portfolio, these clients will be assessed a separate "Investment Management Fee" that is billed quarterly, in advance and based on the market value of the Client's Account on the last day of the month in the prior quarter. These fees will be billed directly from the Client Account and are detailed in the Lionshare documentation authorized by a client signature. The Lionshare Investment Management Fee is separate from any fee to the Financial Advisor and may be billed on a different schedule. We provide an additional service for accounts not directly held in our custody, but where we do have discretion, and may leverage an Order Management System to implement tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k) accounts, HSA’s, and other assets we do not custody. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. This fee will be assessed and billed quarterly. Specifically, the exact amount charged is determined by the daily average over the course of the quarter. The current exception for this is directly-managed held-away accounts, which are determined by the account value at the end of the quarter. In either case, if the Adviser only manages your assets for part of a quarter, the charge will be prorated. The advisory fee is a blended

fee and is calculated by assessing the percentage rates using the predefined levels of assets as shown in the above chart and applying the fee to the daily average of the account value or the account value as of the last day of the previous quarter (per the paragraph above), resulting in a combined weighted fee. For example, an account valued at $2,000,000 would pay an effective fee of 1% with the annual fee being $20,000 (a quarterly fee of $5,00). Investment management fees are generally directly debited on a pro rata basis from client accounts. The exception for this is directly-managed held-away accounts, such as 401(k)’s. As it is impossible to directly debit the fees from these accounts, those fees will be assigned to the client’s taxable accounts on a pro-rata basis. If the client does not have a taxable account, those fees will be billed directly to the client. Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee based on the amount of time remaining in the billing period. An account may be terminated with written notice at least 15 calendar days in advance. Since fees are paid in arrears, no rebate will be needed upon termination of the account. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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 your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Services Limited to Specific Types of Investments AC generally limits its money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, REITs, and government securities. AC may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions AC offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. AC does not participate in any wrap fee programs. E. Amounts Under Management AC has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 184,372,425 $ 25,540,684 December 2023