GeoCapital LLC (“the Company”) is a SEC-registered investment adviser with its principal place of business located in New York. GeoCapital LLC began conducting business in 1979 and currently provides investment advisory services to individuals, their families and related entities, and to an investment adviser. The Company is principally owned by Irwin Lieber, Chief Investment Officer. Separate Accounts GeoCapital LLC provides investment supervisory services and individual portfolio management to individual advisory clients through separately managed accounts, typically with an emphasis on small capitalization stocks. Our firm provides continuous advice to clients regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client's individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. While our focus is on small-cap stocks, these consultations can result in strategies that encompass large cap and income-producing stocks. We manage these advisory accounts on a discretionary basis. Account supervision is guided by the client's stated objectives (e.g., growth, income, or growth and income), as well as tax considerations. The Company's discretionary arrangements include the authority to determine the number of securities to be bought or sold. Such determinations are made with consideration given to the client's investment objectives and/or the client's investment guidelines and constraints. Prudent investment management practices, consistent with client objectives and guidelines, include appropriate diversification of holdings in each account. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors in separate accounts by notifying us in writing. Advisory Services to Investment Advisers to Private Placements The Company also provides investment services on a non-discretionary basis to the management company of certain limited partnerships. These limited partnerships are sponsored by

Buckland Partners Management Co. and are referred to collectively as the Partnerships. Buckland Partnerships: GeoCapital LLC serves as a non-discretionary adviser to affiliates of Buckland Partners Management Co. serving as general partners to the Buckland Partners Focus Fund, LP and the Buckland Partners Growth Fund, LP, referred to collectively as the Buckland Partnerships. The Buckland Partnerships invest primarily in publicly traded securities of micro-capitalization issuers. In addition, they may also invest in privately issued securities, in PIPES or Private Investments in Public Equity. In PIPE transactions, public companies issue stocks and bonds directly and privately to institutional investors. The issuers in which the Buckland Partnerships invest generally have a smaller capitalization than those companies in which the Company invests for its advisory clients. Irwin Lieber, a member of GeoCapital LLC, is a related person of the general partner affiliates of Buckland Partners Management Co. As a result of these relationships, recommendations by GeoCapital LLC and Mr. Lieber to advisory clients to invest in the Partnerships presents the appearance of certain conflicts of interest. GeoCapital LLC receives only reciprocal access to research as a result of these relationships. Nevertheless, GeoCapital LLC endeavors at all times to put the interests of its clients first as part of our fiduciary duty. Potential conflicts, and the steps taken to mitigate them, including foregoing fees on advisory assets invested in the Partnerships, are described further under Items 5 and 10, below. Because the types of investments made by the Partnerships involve certain additional degrees of risk, they typically are not recommended for GeoCapital LLC’s advisory clients and have only been recommended where consistent with the client's stated investment objectives, tolerance for risk, liquidity and other suitability considerations. The risks specific to each fund are detailed in the respective Partnership’s private placement memorandum and other offering materials, which should be read carefully prior to committing funds. Please see Item 8, below, for additional information regarding GeoCapital LLC’s investment strategies and risks. As of 12/31/2023, we actively managed $ 28,867,000 of client assets on a discretionary basis and advised $ 26,347,000 of client assets on a non-discretionary basis.