Invictus Timing Service, Ltd. is a U.S. Securities and Exchange Commission (SEC) registered investment adviser with its principal place of business located in New York. Invictus Timing Service, Ltd. began conducting business in 1986. Jay Allan Ambroson is the firm’s principal shareholder, owning 100% of the company. INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides continuous advice to clients regarding the investment of their funds based on their individual needs. Through personal discussions in which goals and objectives based on their 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. We manage these advisory accounts on a discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker- dealer or insurance company, but our recommendations will generally

include advice regarding open-end mutual fund shares and to a lesser extent exchange traded funds. Individual stock trades are done as a courtesy for the client. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. We have access to a select list of no transaction fee (“NTF”) mutual funds, which enable clients to purchase mutual funds without incurring an upfront transaction or commission expense on the trade. However, other fees may be incurred, as discussed in “Item 5 Fees and Compensation” below. MARKET TIMING SERVICES Invictus Timing Service, Ltd. provides the management of individual clients' portfolios, rendering advice as to the advisability of moving between equity or bond funds or to a defensive fund to capture gains during rising market periods and to preserve the client's capital during falling market periods. Our market timing service is of a continuous nature, evaluating holdings and market positions daily. We will attempt to move funds from one specific fund group to a money market fund when the capital improvement potentiality is in question. The funds will be reallocated when factors indicate growth possibilities. Our primary objective is to preserve and increase the aggregate capital funds of our clients. AMOUNT OF MANAGED ASSETS As of 12/31/2023, we were actively managing client assets on a discretionary basis of $78,000,735.