FIRM DESCRIPTION Overseas Capital Management LLC (hereinafter referred to as “OCM,” “we,” “us,” or “our firm”) is a Delaware limited liability company that was organized in 2020, and its principal office is located in Shanghai, China. The principal owner and Chief Compliance Officer is Bob Olivar. OCM is an investment advisory firm that provides investment and risk-management solutions to clients worldwide. As of December 31, 2023, OCM manages $7,966,435 in assets on a discretionary basis and $0 in non-discretionary assets. Clients may contact OCM for updated information on assets under management. ADVISORY PROGRAMS In connection with our investment advisory services, OCM primarily provides advice with respect to equities (common stocks and equivalents), mutual funds, options, and bonds. Our advice is generally limited to these types of investments, but we reserve the right to advise or not advise our clients on certain investments should we deem it appropriate based on their particular circumstances. For more information on our investment strategies, please refer to the “Methods of Analysis, Investment Strategies and Risk of Loss” section of this Brochure. OCM’s advisory services are tailored to the needs of our clients based on their individual investment objectives, risk tolerances, cash or income needs, and any investment restrictions. Although OCM seeks to accommodate reasonable investment restrictions or guidelines set by our clients, we may decline to accommodate certain investment restrictions that are incompatible with our firms’ investment philosophy or that may have an adverse effect on our ability to manage a client account. Bob Olivar serves as OCM’s sole investment adviser representative and the firm’s Chief Compliance Officer. Clients should refer to Form ADV Part 2B (the “Brochure Supplement”) for more information about his qualifications. OCM enters into formal written agreements with our clients setting forth the terms and conditions under which we will provide our advisory services (the “Investment Management Agreement”). Our advisory agreement(s) sets forth the scope of the services to be provided and the compensation we receive from the client for such services. Investment Management Services. OCM provides investment management services to our clients where client portfolios are managed according to the client’s state investment goals and objectives. We provide investment management services in which clients grant our firm the ability to utilize

discretion in managing their investment account(s). The client grants our firm full power to direct, manage, and change the investment and reinvestment of the assets in the account, the proceeds, and any additions. Our authority over the client’s investments includes discretionary authority to purchase and sell securities for the client’s account, to submit aggregated trade orders for the client and others in order to obtain best execution, and to give instructions concerning these transactions to the qualified custodian with which the client’s account(s) are held. We are not required to first consult with the client before placing any specific order or obtain specific authorization from the client for each specific transaction. We receive discretionary authority from our clients through our investment management agreement (the “IMA”) at the outset of our advisory relationship. We generally do not manage accounts on a non-discretionary basis. We may, however, from time to time make an exception upon client request. Retirement Rollovers. The Department of Labor’s Prohibited Transaction Rule 3.0 establishes that advice to rollover or transfer an account is fiduciary advice even though the prospect is not a client. ERISA fiduciaries are subject to the prohibited transaction rules, primarily 2020-02 which prohibits self-dealing. The Prohibited Transaction Rule 3.0 requires four elements of disclosure: 1. Affirmation of ERISA fiduciary duty 2. Description of services to be provided 3. Disclosure of material conflicts of interest 4. Explanation of the reasons for the recommendation and how it is in the Retirement Investor’s best interest Before making a recommendation to execute a rollover, OCM will consider the following factors when evaluating whether a rollover is in the best interest of our client: the alternatives to a rollover including leaving the money in the plan or account type, comparative fees or expenses, whether an employer or other party pays for some or all administrative expenses. Depending on the circumstances, OCM may identify other factors relevant to this analysis as well. Overseas Capital Management LLC has and always will act as a fiduciary for clients and prospective clients when reviewing a retirement rollover or transfer of account. Important Note: It is the Client’s responsibility to ensure that OCM is promptly notified if there are ever any significant changes to their financial situation, goals, objectives or needs so we can review our previous recommendations and make any necessary adjustments.