Patriot Asset Management, Inc. is a corporation organized in the state of New York. The firm was formed in November of 2012, and as of September of 2017, the principal owner is Gerard C. Murray. Patriot Asset Management filed its initial application to become registered as an investment adviser with the U.S. Securities Exchange Commission in September 2021, which was accepted on November 1, 2021. Patriot Asset Management, Inc. (hereinafter “PAM”) offers the following services to advisory clients: Investment Supervisory Services PAM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. PAM 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 strategy 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
• Asset allocation
• Risk tolerance
• Personal investment policy
• Asset selection
• Regular portfolio monitoring PAM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. PAM will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Retirement Plan Rollover Recommendations When PAM provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, we acknowledge that PAM is a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. The way PAM makes money creates conflicts with your interest, so PAM A. Description of the Advisory Firm B. Types of Advisory Services operates under a special rule that requires PAM to act in your best interest and not put our interest ahead of you. Under this special rule’s provisions, PAM must as a fiduciary to a retirement plan account or IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (e.g., give prudent advice);
• Never put the financial interests of PAM ahead of you when making recommendations (e.g., give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that PAM gives advice that is in your best interest;
• Charge no more than is reasonable for the services of PAM; and
• Give Client basic information about conflicts of interest. To the extent We recommend you roll over your account from a current retirement plan account to an individual retirement account managed by PAM, please know that PAM and our investment adviser representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an

IRA managed by PAM. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by PAM. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in PAM receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by PAM and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to your regarding a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of PAM or our affiliated personnel. Services Limited to Specific Types of Investments PAM generally limits its money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, REITs, and government securities. PAM may use other securities as well to help diversify a portfolio when applicable. PAM offers the same suite of services to all of its clients. However, specific client financial strategies and goals 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 specific strategy to aid in the selection of a portfolio that matches restrictions, needs, and targets. 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 PAM from properly servicing the client account, or if the restrictions would require PAM to deviate from its standard suite of services, PAM reserves the right to end the relationship. 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. PAM does not participate in any wrap fee programs. Patriot Asset Management, Inc. has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $28,409,986 $0 06/30/2023 C. Client Tailored Services and Client Imposed Restrictions D. Wrap Fee Programs E. Amounts Under Management