Smith Affiliated Capital Corp. (“SAC”, the “firm”, “we”, “our” or “us”), founded in 1982 by Robert G. Smith, Ph.D., is a registered investment advisory firm based in New York City. SAC is a wholly-owned subsidiary of Smith Affiliated Ventures L.L.C. (“SAV”), a New York limited liability company, of which the majority owner is Maria Smith and the other owners are senior management employees. SAC provides investment advice for separately managed portfolios of individuals, including high net worth individuals and institutional investors, including, public and corporate retirement plans, corporations, foundations, government entities and as an investment sub-adviser to one or more third- party investment advisers. SAC has numerous investment styles structured to meet the individual needs of a client (a “client” or “you” or “your”) and focuses on taxable and tax-exempt fixed income securities as well as equity investments using individual stocks and ETFs. Investment strategies can be tailored to meet a variety of investment constraints and objectives. Our services can be further tailored to meet a client’s imposed near and long-term liabilities, cash management, liquidity or asset allocation restrictions. Please see Item 8 - Methods of Analysis, Investment Strategies, Process and Risk of Loss, for more information on these styles. As of December 31, 2023, SAC managed $1,796,102,202 in regulatory assets under management, $950,586,116 of which is managed on a discretionary basis and $845,515,976 of which is managed on a non-discretionary basis. We offer our management services on a fee basis as a percentage of assets under management. Please see Item 5 - Fees and Compensation for more information. Prior to engaging SAC, the client will be required to enter into a written agreement setting forth the terms, conditions, and objectives under which we shall render our services as well as the fees for our management services. Discretionary Management Services When providing discretionary services, we have the authority to make investment decisions on behalf of our clients, including which securities to buy and sell (referred to as “discretionary authority”) consistent with each client’s objectives and guidelines. Discretionary authorization allows our firm to determine the specific securities,

and the amount of securities, to be purchased or sold without client approval prior to each transaction. Our discretionary authority can be limited by the written investment policy statement (“IPS”) that is provided to SAC, or as otherwise agreed upon by SAC and the client at the inception of SAC’s provision of advisory services. SAC separately manages investment portfolios to seek to meet each individual client’s stated objectives and risk tolerances as communicated to SAC at the beginning of our advisory relationship. Typically, portfolios will align with one or more of our investment strategies as illustrated by our investment composites. Portfolio investments and performance are actively managed and monitored on an ongoing basis. Portfolios are rebalanced as required by changes in market conditions and/or a client’s financial circumstances to the extent communicated to SAC. SAC does not participate in any wrap fee programs at this time. Non-Discretionary Advisory Services SAC also provides non-discretionary advisory services to clients. In providing these services, SAC may advise on a wide variety of topics, which may include, but are not limited to, advising on the benefits of increasing contributions and other information relating to a particular investment, such as details on the available investment options (e.g., risk and return characteristics, historical return information, prospectus terms, etc.), concepts such as types of risk (market, inflation, etc.), diversification, dollar cost averaging and compounding, and general information about asset classes as well as time horizons, risk tolerance levels, and retirement income needs. SAC may also provide clients with asset allocation modeling, which involves providing clients with examples of diversified portfolios based on certain investor profiles. This information may include charts, spreadsheets, and/or case studies that pertain to hypothetical individuals with differing time horizons and risk profiles. In providing non-discretionary services, SAC may make recommendations to the client concerning matters such as asset allocation, liability analysis, investment policy, tax-efficient investment planning, crossover investing, second opinions, investment diagnostics, portfolio monitoring, and investment execution.