Page 4 A. Avocet Capital Management LLC Avocet Capital Management LLC (“Avocet” or the “firm”) is a single, individual member Illinois limited liability company. Alan Loewy is the sole member. Avocet offers investment advisory and financial planning services to its clients. B. Advisory Services Offered Avocet is an independent asset management and financial planning firm offering a variety of financial services to various types of clients, including individuals and high-net-worth individuals, trusts and estates, corporations and other businesses. Discretionary Asset Management Services Avocet's Investment Advisory Services consist of its management of client accounts on a discretionary basis. For its discretionary asset management services, Avocet receives a limited power of attorney to effect securities transactions on behalf of its clients that include securities and strategies described in Item 8 of this Brochure. In addition, Avocet will remind clients of their obligation to inform Avocet of any changes to their financial circumstances, investment objectives or risk tolerance or of any modifications or restrictions that should be imposed on the management of the client’s account. Avocet will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. Avocet will structure a portfolio based on an assessment of the client’s financial situation, return expectations, sensitivity to volatility, and an assessment of the economic and market environment. The client may impose reasonable restrictions concerning the management of his or her account(s). Financial Planning Services Avocet offers its financial planning services on an hourly basis. Clients will receive a written or oral report (depending on the client’s preference), providing the client with a detailed financial plan designed to help achieve the client’s stated financial goals and objectives. Generally, any of the categories below require a minimum of ten hours to compile the necessary data to formulate recommendations. Based on the client’s needs, financial planning services may include, but are not limited to, the following:  Preparation of a recommended asset allocation that serves to diversify the client's portfolio among different categories of investments such

as small, medium, and large capitalization securities; corporate and government fixed income (short, intermediate, and long-term maturities); emerging market securities (i.e., foreign issuers); and such other asset categories that are suitable in light of the client's investment goals, objectives, and risk tolerance.  Preparation of an investment policy statement setting forth the investment plan of the client with specific direction in terms of diversification requirements, tax issues, estate planning issues, risk tolerance, retirement, and other identified objectives of the client, including a targeted rate-of- return objective.  Preparation of a retirement plan that serves to identify whether the client is saving enough and investing in a way that meets retirement objectives in light of the client's financial circumstances and risk tolerance. Page 5  Preparation of cash flow projections to ensure the client is able to meet daily living expenses and obligations.  Preparation of an estate plan to ensure that wealth transition, tax, and related issues are met in accordance with the client's wishes. In many instances, an outside attorney will need to be hired to handle specific legal issues that arise in the formation and implementation of an estate plan. Avocet gathers required information through in-depth personal interviews and questionnaires. Information gathered include a client's current financial status, investment objectives, future goals, and attitudes toward risk. Related documents supplied by the client are carefully reviewed, and a report is prepared covering one or more of the above-mentioned topics as directed by the client. C. Client Tailored Services and Client Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives, and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs Avocet does not participate in wrap fee programs. (Wrap fee programs offer services for one all-inclusive fee.) E. Client Assets Under Management As of December 31, 2022, Avocet had $102,962,581 of discretionary assets under management and $3,129,763 of non-discretionary assets under management. Item 5: Fees and Compensation