A. Firm Description BRM Investment Management, LLC, (“BRM Investment Management,” “BRMI” or “the Firm”) also doing business as Massey Romans Capital; is an investment management firm that is registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser based in Vero Beach, FL. The Firm’s registration as an investment adviser does not imply a certain level of skill or training. The Firm is organized as a Delaware limited liability company that was founded in 2022. BRM Investment Management’s current business activities consist:
• Portfolio Management Services
• Financial Planning/Consulting Services Principal Owner: William B. Brown (50%), Paul Massey (25%), and William Romans (25%) are principal owners. The Firm also operates under the name, Formidable Florida. B. Types of Advisory Services PORTFOLIO MANAGEMENT SERVICES BRM Investment Management offers personalized investment advisory services which are focused on providing a roadmap of income and expenses over our client’s life. Our advice and services are tailored to meet our client’s individual needs, circumstances and goals. We offer our portfolio management services through both discretionary and non- discretionary management. We conduct initial meetings with clients in order to understand their current financial situation, existing resources, goals, objectives and risk tolerances. Discretionary Portfolio Management: The primary service we provide is discretionary asset management program. Clients participating in this program are generally placed in a strategy or allocation that is overseen by financial professional at our Firm and sub- advised by a third-party investment adviser. Under this program, BRM Investment Management and any sub-advisers we hire to manager the assets in your account are authorized to buy and sell investments in the account without asking you in advance. We monitor the portfolio on an ongoing and continuous basis, unless otherwise agreed, and will make adjustments and reallocations as necessary due to changes in the market and your unique circumstances. Clients may impose certain reasonable written restrictions on BRM Investment Management in regards to the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments. Each client should take note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client’s investment portfolio. Non-Discretionary Portfolio Management: Alternatively, BRM Investment Management provides non-discretionary portfolio management services whereby the Firm will make specific investment recommendations to a client tailored to meet the needs and investment objectives of that specific client but shall not initiate any orders to purchase or sell any securities (or specific securities) without the client’s approval. This program offers clients the opportunity to maintain full investment authority and direct the individual investments made within their own accounts. As part of our investment advisory services to you, we may recommend that you withdraw the assets from your employer's retirement plan and roll the assets over to an individual retirement account ("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset- based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan

before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of: 1)) Leaving the funds in your employer's (former employer's) plan; 2) moving the funds to a new employer's retirement plan; 3) cashing out and taking a taxable distribution from the plan; and/or 4) rolling the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. Our recommendations may include any of them, depending on what we feel is in your best interest. We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also 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. As a fiduciary, we are required to document the reason(s) for why the recommendation we made is in your best interest. FINANCIAL PLANNING AND CONSULTING SERVICES BRM Investment Management provides financial planning and consulting services for clients seeking financial advice involving the analysis of a particular investment, investment portfolio, or overall financial situation. The consulting services typically take the form of a financial plan. These consulting services may include, but are not necessarily limited to, a review of aspects of an individual’s current financial situation, with emphasis on portfolio analysis, estate planning, insurance planning, education planning and/or capital needs planning. BRM Investment Management may also assist the client in coordinating the implementation of any recommendations made. The decision to implement any recommendation rests exclusively with the client, and the client has no obligation to implement any such recommendations through BRM Investment Management or its affiliates. In preparing the financial plan for a client, BRM Investment Management will gather information deemed relevant to the particular advisory services being provided through fact-finding reviews with the client and through documents provided by the client. The service includes an analysis of the client’s financial information, which may include items such as the client’s current assets, income, investments, liabilities, short and long-term capital and liquidity needs, risk tolerance and short and long-term financial goals and objectives. C. Tailored Relationships The investment advisory services offered by BRM Investment Management are based on the individual needs of our clients and the suitability of products and services. We make an assessment of our client’s goals, objectives, investment horizon, and risk tolerance. If clients wish to impose certain restrictions on investing in certain securities or types of securities, the Firm will address those restrictions with the clients to have a clear understanding of the client’s requirements. As the client’s financial situation, goals, objectives, or needs change, the client must notify BRM Investment Management promptly. D. Wrap Fee Programs Wrap Fee Programs are arrangements between broker-dealers, investment advisers, banks and other financial institutions and affiliated and unaffiliated investment advisers through which the clients of such firms receive discretionary investment advisory, execution, clearing and custodial services in a “bundled” form. In exchange for these “bundled” services, the clients pay an all-inclusive (or “wrap”) fee determined as a percentage of the assets held in the wrap account. BRM Investment Management does not participate in and is not a sponsor of any wrap fee program(s). E. Assets under Management As of February 22, 2023 the Firm has $ $132,880,104 in assets under management, all of which are discretionary.