Description of Firm Gunderson Capital Management, Inc ("GCM"), d.b.a. Gunderson Capital, is a Charleston, South Carolina based investment advisory firm registered as an investment adviser and is organized under the laws of the state of South Carolina as a corporation. GCM offers customized investment management services to individuals and high net worth individuals. GCM offers market commentary, forecasts and analysis in Bill Gunderson’s “Best Stocks NOW! Book and Newsletter”, to which persons may subscribe for a subscription fee. GCM also offers stock rankings on over 3,500 stocks through the “Best Stocks NOW! App”, to which persons may subscribe for a subscription fee. Principal Owners GCM is 100% owned by William Gunderson, who serves as the Firm’s President, Chief Investment Officer. Types of Advisory Services Offered Each portfolio is individually tailored to meet the individual client’s long-term financial objectives and within his or her risk tolerance based upon the information provided by the client to GCM. GMC requires Client accounts to be held at Charles Schwab. Charles Schwab will maintain physical custody of Client funds and securities. GCM does not act as custodian and GCM does not have access to Client accounts except to have advisory fees deducted from Client accounts by the custodian with prior written authorization. GCM will not assume any responsibility for the accuracy of the information provided by the client. GCM is not obligated to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. Under all circumstances, clients are responsible for promptly notifying GCM in writing of any material changes to the client’s investment guidelines. In the event that a client notifies GCM of changes, GCM will review such changes and recommend any necessary revisions to the client’s portfolio. GCM’s representatives will generally meet by telephone with clients periodically to review the client’s investment goals and current advisory portfolios. Advisory representatives are also available during normal business hours to consult with clients. GCM will manage client portfolios investing in equities (stocks), warrants, corporate debt securities, investment company securities, and mutual funds shares. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The brokerage firm charges a fee for securities transactions. GCM does not receive any compensation, in any form, from the brokerage firm or fund companies. When a client grants GCM investment discretion, GCM will have authority to determine without specific client consent the (1) securities to be bought and sold; (2) the amount of securities to be bought and sold; (3) the broker or dealer to be used; and (4) the commissions to be paid. Mr. Gunderson hosts a daily radio show from 7:00am to 8:00am on the Wall Street Business Network currently broadcast in seven states called the “Best Stocks NOW! Radio Hours in which Mr. Gunderson provides market commentary, analysis, opinions and gives examples of stocks to consider. GCM offers market commentary, forecasts and analysis in Mr. Gunderson’s “Best Stocks NOW! Book and Newsletter”, to which persons may subscribe for a subscription fee. Published on a week basis, the newsletter encompasses a variety of material-based Mr. Gunderson’s insight derived from tracking approximately 3,600 different stocks, ETFs, and closed-end

funds and his watching trends in commodity prices, the dollar, shifts in interest rates, and the unfolding of international events that affect the markets. GCM also offers stock rankings on over 3,500 stocks through the “Best Stocks NOW! App”. Neither Mr. Gunderson nor GCM guarantees any specific outcome and any recommendations may not be suitable for certain investors given that the radio show, newsletter and application do not take into account any subscriber’s or listener’s particular investment objectives and financial situations. GCM does not offer or participate in “wrap-fee” Programs. GCM offers the same suite of services to all of its clients. However, specific client investment strategies 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). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. [However, if the restrictions prevent GCM from properly servicing the client account, or if the restrictions would require GCM to deviate from its standard suite of services, GCM reserves the right to end the relationship.] Investment Advisory Agreements Prior to engaging GCM to provide investment management, the client will be required to enter into an investment management agreement with GCM setting for the terms and conditions under which GCM shall render services. A Client may terminate the agreement at any time by notifying GCM in writing. If the client made an advance payment, GCM will refund any unearned portion of the advance payment in a timely manner. GCM may terminate the investment management agreement at any time by notifying the client in writing. If the client made an advance payment, GCM will refund any unearned portion of the advance payment in a timely manner. GCM reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in GCM’s judgment, to providing proper financial advice. Any unused portion of fees collected in advance will be refunded in a timely manner. Neither GCM nor the client may assign the investment management agreement without the prior written consent of the other party. Transactions that do not result in a change of actual control or management of GCM shall not be considered an assignment. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning will be offered to asset management clients. In offering financial planning, a conflict exists between the interests of the investment adviser and the interests of the client. The client is under no obligation to act upon the investment adviser's recommendation, and, if the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through the investment adviser. Live Seminars The firm travels in the areas where their radio show is broadcasted and provides seminars at no charge. Assets Under Management As of December 31, 2022, the following represents the amount of client assets under management by GCM: Type of Account Assets Under Management ("AUM") Discretionary $197,826,292 Non-Discretionary $ 0.00 Total: $197,826,292