A. Firm Background Townsend Asset Management Corp was established in 1982 by Gerald and Katrina Townsend. It is registered with the SEC as an investment advisor. Townsend is an independent firm and is not affiliated with any other entity. B. Advisory Services Our services include: a. Investment Management Ongoing management of your investment portfolios, based on your goals and needs. The firm follows a disciplined process comprised of the following steps: i. Goal Setting – Understanding your personal and financial goals. ii. Resources – Reviewing your assets, income, and other financial resources. iii. Constraints – Identifying Items affecting management. 1. Your time frame for investing 2. Your need for liquidity or marketability of your investments 3. Tax or legal considerations 4. Your income requirements 5. Your diversification needs. 6. Your age, health, or other personal matters iv. Economic Considerations – Developing a domestic and international economic outlook, as well as a viewpoint on government monetary and fiscal policy. v. Investment Policy – Developing an overall policy regarding your investments that serves as a guide to the management of their portfolio. vi. Asset Allocation – Spreading your investments among different classes of assets, such as: cash equivalents; short, intermediate or long-bonds; small or large capitalization stocks; foreign stocks or bonds; mutual funds; etc. vii. Security Selection – Determining and acquiring your specific investments. viii. Performance Reporting – In addition to statements provided by the custodian or brokerage firm, Townsend provides quarterly performance and asset allocation reports. ix. Ongoing Management - Monitoring your portfolio and making changes when necessary. This also involves meetings or other communication regarding your investments or changes in your goals or resources. Part 2A of Form ADV: Firm Brochure Date: 03/4/2024 5 of 19 b. Financial Planning Financial planning covers some or all the following: i. Personal and family goals and life issues ii. Budgeting and cash flow management iii. Income tax planning iv. Risk management and insurance needs analysis v. Retirement planning and strategies for funding and withdrawal vi. Employee benefits review vii. College education funding strategies viii. Business analysis and planning ix. Asset protection planning x. Asset allocation and investment advice xi. Estate conservation and distribution strategies c. Tax Preparation and Planning Townsend prepares federal and state income or other tax returns for individuals, businesses, and other entities. d. Consulting Townsend consults with clients on a broad range of financial, tax, retirement, estate, and investment matters. e. Wealth Management This is a term Townsend uses to describe a comprehensive service that includes our Investment Management, Financial Planning, Tax Preparation and Consulting services,

under a single fee arrangement. f. Retirement Plan Rollovers – No Obligation / Conflict of Interest A client or prospective client leaving an employer has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Townsend recommends that a client roll over their retirement plan assets into an account to be managed by Townsend, such a recommendation creates a conflict of interest if Townsend will earn new (or increases its current) compensation as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by Townsend. Part 2A of Form ADV: Firm Brochure Date: 03/4/2024 6 of 19 C. Services Based on Client Needs Our services are tailored to each client’s individual needs. In initial meetings we gather personal and financial information and discuss short- and long-term goals, preferences, or restrictions, as well as what services you need and what your expectations are in a client-advisor relationship. From this, we jointly determine the services that would be most beneficial to the client and how to best structure the delivery of those services. For example: The client may impose a restriction against investing in a certain security or a particular type of security and we would avoid that security or types of securities. Conversely, the client may indicate a preference for including certain securities or types of securities in your portfolio. D. Wrap Fee Programs Townsend does not participate in any wrap fee programs. Assets Managed The firm can manage accounts on either a “discretionary” or a “nondiscretionary” basis, although normally it is on a discretionary basis. When managing on a discretionary basis, Townsend is permitted to determine, without obtaining the specific consent of the client, the securities, and the amounts to be bought or sold Discretionary management is useful for an advisor, due to the time needed if prior approval is required before implementing each transaction in your account. In addition, Townsend manages client portfolios in accordance with the client’s expressed goals and the investment policy mutually agreed upon. Finally, through a custodian’s confirmations and statements, our own reporting, and other forms of communication, clients are always kept apprised of transactions within their accounts. As of 12/31/2023, the assets the firm manages are as follows: Managed on a discretionary basis $358,965,144 Managed on a nondiscretionary basis $42,442,824 Total assets managed $401,407,968 Part 2A of Form ADV: Firm Brochure Date: 03/4/2024 7 of 19