George McKelvey Co LLC (“GMCo”) is a fee-based SEC-registered investment adviser with its principal and only place of business located in Manasquan, New Jersey. We have been in business since 1960. Robert G. McKelvey, Robert A. Giunco, Jr., and Richard Looney are the current members of the LLC. Discretionary assets under our firm’s management were $1,014,607,244 as of December 31, 2023. Non-discretionary assets under our firm’s management were $33,197,775 as of December 31, 2023. Portfolio Management Services GMCo is in the business of managing portfolios with individually tailored investment strategies. Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives are established based on a client's particular circumstances, we develop a client's personal investment policy and create and manage a portfolio based on that policy. Our data-gathering process includes the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. We usually review and discuss a client’s prior investment history, as well as family composition and background. We will manage advisory accounts primarily on a discretionary basis. For discretionary accounts, we will implement transactions without seeking prior client approval, with occasional exceptions, depending on the specific agreement with the client. For non- discretionary accounts, we will seek prior client consent for every contemplated transaction. Therefore, clients with non-discretionary accounts should understand that any delay in obtaining consent may result in different and potentially less favorable transaction terms, including higher security price and/or limited availability of the securities sought. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income, safety and liquidity), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Clients will generally have the following instruments in their investment portfolios:  Individual equity securities  Fixed income securities  No-load, load-waived and load-bearing mutual funds  Exchange Traded Funds (ETFs)  Other security types Financial Planning/Consulting Services Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information and analysis will be considered as they impact and are impacted by the entire financial and life situation of the client. We gather information through in-depth personal interviews. Information gathered includes a client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. Should a client choose to implement the recommendations, we suggest the client work closely with his/her attorney, accountant, insurance agent, and other professionals. Implementation of financial plan recommendations is entirely at the client's discretion. Our financial planning/consulting recommendations are not limited to any specific product or service. Clients can also receive investment advice on a more limited basis. This may include advice on only an isolated area(s) of concern such as estate

planning, retirement planning, insurance issues or any other specific topic. GMCo does offer consulting on 401k retirement plans to assist individuals in selecting their investments within the plan in accordance with the client’s goals for retirement. Wrap Program GMCo includes certain transactional costs in the client’s management fee. This arrangement is referred to as a “Wrap Program”. For accounts in the Wrap Program, we pay a fee to the custodian based on the clients’ transaction costs. Fees in the Wrap Program include transaction costs for the purchase or sale of securities, but do not include expenses related to the use of margin, wire transfer fees, the fees charged to shareholders of mutual funds or ETFs, mark-ups and mark-downs, spreads, odd-lot differentials, fees charged by regulatory agencies, and any transaction fees for securities trades executed by a broker- dealer other than the agreed upon custodian. Expenses for the management fees of third- party managers are also not included in the Wrap Program, and to the extent utilized, the client will be responsible for such fees. Because we will be managing the assets of wrap fee program clients the same way as other non-wrap fee program clients, the use of external portfolio managers within the wrap program is expected to be limited. To the extent a third-party manager is utilized, the fees payable to such managers will not be included in the Wrap Program. Therefore, there is no difference between how we manage wrap fee accounts and how we manage other accounts. Because of the nature of a wrap program, wherein clients pay one fee for advisory services as well as certain transactions, the actual compensation to the firm will vary as the transaction costs charged to the program vary. This means that if transaction costs go down, either because the account is traded less or because the cost per trade goes down, the firm’s compensation for the same advisory services will increase. Likewise, if the costs increase, the firm’s advisory compensation will decrease. Also, because of the nature of a Wrap Program, where wrap fees are not tied to an account’s frequency of trading and apply to generally all assets in the account, the wrap fee program client may pay more or less than if the client had compensated us outside of the Wrap Program. For example, if a client’s account is rarely traded, the transaction fees the client would have paid would be minimal, thus limiting the benefits of “wrapping” management fees and transaction fees. Clients whose accounts will be rarely traded should carefully consider whether the Wrap Program is appropriate. We receive a portion of the wrap fee for our services. We do not engage other portfolio managers to manage assets within the Wrap Program. To the extent a third-party manager is utilized, the fees payable to such managers will not be included in the Wrap Program. We are the sole portfolio manager in the Wrap Program, which means we receive a portion of the wrap fee for our services. Transaction fees are paid to various broker-dealers, mutual funds and ETFs. The remainder of the wrap fee is the management fee payable to us. We will receive no additional compensation for offering the Wrap Program. Please see the Wrap Fee Brochure for a more complete description of the Wrap Program. Services in General We tailor all of our portfolio management, financial planning, and consulting recommendations to the individual needs of each client. All such recommendations are based on information gathered through client questionnaires, telephone, electronic communications and in-person discussions.