Firm Description Capital Advisors is primarily engaged as an investment advisory firm which gives general and specific investment advice to individuals, high net worth individuals, institutions, pension and profit-sharing plans, charitable organizations, investment companies and corporations and other business entities. Capital Advisors was founded in 1978. Principal Owners Capital Advisors’ owners include Keith Goddard via Keith C. Goddard Revocable Trust and G. (Andy) Brown. Types of Advisory Services Capital Advisors offers the following types of advisory services: Portfolio management for individuals and/or small business, portfolio management for investment companies, and portfolio management for businesses or institutional clients. Investment Advisory Services Capital Advisors’ Investment Advisory Services are provided in a comprehensive approach. The Firm’s Investment and Research Committee (The Committee) is responsible for the development and daily management of portfolio strategies. The Committee is responsible for the research and selection of each security within each strategy. The Committee meets on a weekly basis, at minimum, to review portfolio strategies. Capital Advisors’ Investment Advisory Services are further provided by Portfolio Management teams comprised of an Investment Advisor Representative, an internal portfolio manager and a client services associate. The Portfolio Management team has ongoing responsibility for maintaining the relationship with the client. The Portfolio Management team ensures that each client is provided with an appropriate portfolio strategy based upon their specific investment objectives and stated risk tolerance. The client services associate serves as a liaison between Capital Advisors and the client’s custodian to facilitate the processing of administrative documents and other administrative duties. This generally includes the following: A consultation with the client to ascertain investment objectives, risk tolerance, time horizon and life goals.
• Developing an asset allocation plan or model portfolio to align the client’s investment objectives with the most efficient and effective investment vehicles to attain those objectives.
• Selection and presentation of an investment strategy to the client.
• Implementing the investment strategy by establishing investment accounts, selecting custodians if necessary, transferring client assets, and establishing trading and data procedures.
• Monitoring investment selections, including adjustments or rebalancing of investments as necessary to meet the client’s changing needs.
• Providing information regarding investment philosophies, specific investment vehicles, and other areas to enhance the client’s knowledge.
• Reporting portfolio information, including holdings and investment performance to the client. Financial Planning Services Capital Advisors provides comprehensive financial planning services. Our advice is tailored to meet the individual needs of each client, depending on the specific needs and circumstances as requested by each client. Our comprehensive financial planning services are not specific to one particular type of advice. Instead, we advise on a wide variety of financial issues which may include college funding, estate planning, tax planning, insurance, asset allocation, retirement planning, 401ks, and investment selection. 5 Capital Advisors, Inc. Capital Advisors uses one or more licensed software programs to facilitate the financial planning services and does not include any tax or legal advice with our financial plans. Where a discussion would include insurance products, only appropriately licensed individuals may participate in the advice offered. Investment Companies (Mutual Funds) Capital Advisors serves as investment adviser to the Capital Advisors Growth Fund (CIAOX), (the Fund). The Fund is a diversified open-end investment company registered under the Investment Company Act of 1940. The Fund is a series of Advisors Series Trust. U.S. Bancorp Fund Services, LLC provides administration accounting and transfer agency services to the Fund. U.S. Bank, N.A. is the custodian of the assets of the Fund. Capital Advisors does not actively market the Fund. It is offered as an alternative in the event a client’s investment objective matches our Managed Equity Growth strategy but does not meet the minimum criteria for the strategy. Capital Advisors does not charge a separate investment advisory fee for the shares held within a portfolio. The Firm receives a management fee from the Fund; fees are disclosed in the Fund prospectus. The Fund is treated as a client and managed in the same manner as any such client that might participate in the strategy. The holdings of the Fund are block traded with clients holding the strategy. All fund shareholders receive annual audited financial statements as well as delivery of the prospectus by the Fund. Tax Consulting Capital Advisors also consults with clients on tax matters. Capital Advisors does not offer tax preparation services. Tailored Relationships Capital Advisors tailor’s investment advisory services to the individual needs of the client. The goals and objectives for each client are documented in our client relationship management

system. Capital Advisors’ clients are allowed to impose restrictions on the investments in their account. Capital Advisors may accept any reasonable limitation or restriction to discretionary authority on the account placed by the client. All limitations and restrictions placed on accounts must be presented to Capital Advisors in writing. Fiduciary Statement Capital Advisors is a fiduciary under the Investment Advisers Act of 1940 and when Capital Advisors provides investment advice to clients regarding their retirement plan accounts or individual retirement accounts, Capital Advisors is also a fiduciary 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. Capital Advisors is required to act in each client’s best interest and not put their interest ahead of clients at the same time, the way Capital Advisors makes money creates some conflicts with client interests. Capital Advisors must take into consideration each client’s objectives and act in the best interests of the client. Capital Advisors is prohibited from engaging in any activity that is in conflict with the interests of the client. Capital Advisors has the following responsibilities when working with a client:
• Render impartial advice;
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put their financial interests ahead of clients when making recommendations (give loyal advice);
• Make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• Avoid misleading statements about conflict of interest, fees, and investments; 6 Capital Advisors, Inc.
• Have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Follow policies and procedures designed to ensure that Capital Advisors give advice that is in your best interest;
• Charge no more than is reasonable for services;
• Provide clients with basic information about conflicts of interest; and
• Treat clients fairly and equitably Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. Capital Advisors will act with competence, dignity, integrity, and in an ethical manner, when dealing with clients. Capital Advisors will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Wrap Fee Programs Capital Advisors participates in wrap fee programs. A “wrap-fee” program is one that provides the client with advisory and brokerage execution services for an all-inclusive fee. The client is not charged separate fees for the respective components of the total service. In evaluating wrap fee programs, clients should consider that, depending upon the level of the wrap fee charged, the amount of portfolio activity in the client’s account, the broker dealer's usual commission rates and other factors, the wrap fee may be more or less than the aggregate cost of such services if they were to be provided separately and if Capital Advisors were to negotiate commissions and seek best price and execution of transactions for the client's account. The advisory fee is negotiable between the client and Capital Advisors and is set out in the advisory agreement. The advisory fee is a percentage based on the value of all assets in the account, including cash holdings. The advisory fee may be higher than the fee charged by other investment advisors for similar services. Further, clients should be aware that the person recommending the program to the client may receive compensation as a result of the client’s participation in the program, that the amount of this compensation may be more than what the person would receive if the client participated in other programs of the sponsor or paid separately for investment advice, brokerage, and other services, and that the person may therefore have a financial incentive to recommend the wrap fee program over other programs or services. The investment products available to be purchased in the program can be purchased by clients outside of a program account, through broker-dealers or other investment firms not affiliated with Capital Advisors. Clients should refer to each program’s Form ADV Part 2A Appendix 1 for more information regarding the wrap fee program and related fees. There are no material differences between Capital Advisors’ managed wrap accounts and other accounts. The wrap relationship exists primarily because of the preference of some clients not to be subject to separate transaction charges. Client Assets As of December 31, 2023, Capital Advisors managed $5,501,719,930 in assets. $5,039,682,364 is managed on a discretionary basis, and $462,037,566 is managed on a non-discretionary basis. 7 Capital Advisors, Inc.