A. Description of Advisory Business Makrod Investment Associates, Inc. (“Makrod” or the “Company”) is an investment advisory firm based in Verona, New Jersey. Makrod provides non-discretionary investment advisory services to clients who include high net worth individuals, pension and profit-sharing plans, individuals, trusts and charitable organizations. Makrod has been in business since 1974. The Company is 100% owned by Kathryn O’Donnell, who serves as President and investment adviser as well as the Company’s Chief Compliance Officer. Her husband, Benedict Schlatter, also serves as an investment adviser. B. Types of Advisory Services Makrod Offers Makrod provides investment advisory services to clients through separately managed accounts generally on a non-discretionary basis. Makrod’s clients (“Clients”) are charged fee rates based upon a percentage of their assets under management. Makrod provides recommendations on long term investments in equities as well as on fixed income investments using fundamental analysis and a value-based approach. The investments are intended to be tailored to the needs of the clients. Generally speaking, Makrod constructs portfolios around three types of investments: equities, fixed income and cash/money market funds, though from time to time Makrod will provide advice on other types of investments, such as limited partnerships, mutual funds, certificates of deposit, etc. Within equity securities, Makrod primarily favors investments in blue chip listed securities paying dividends using a long-term purchase strategy (holding for greater than one year). Makrod also provides advice on fixed income securities, primarily investment grade. Within fixed income, Makrod provides advice on United States government

securities (such as U.S. Treasuries), municipals bonds and corporate bonds. Makrod recommends an investment strategy rather than a trading strategy: equity investments are generally recommended as long-term purchases (the securities should be held at least a year) and bond investments are recommended to be held to maturity. Nevertheless, from time to time Makrod may recommend that these securities be sold sooner than anticipated due to unforeseen events (e.g., recommending that securities be sold within a year of purchase). Makrod does not generally broker life insurance nor use options or futures as an investment strategy unless requested by the Client. C. Tailoring of Advisory Services Makrod tailors the advisory services to the individual needs of Clients by recommending investments to Clients on a non-discretionary basis and by discussing potential investment decisions with each Client. The Clients sign a limited power of attorney with their custodians/broker-dealers allowing Makrod to place trades in the Clients’ accounts, and Makrod contacts the Clients for their authorization to place trades. Clients may impose restrictions on investing in certain securities or types of securities by modifying the recommended investments as they see fit. Clients may request that Makrod purchase or sell specific securities for their accounts which Makrod would not otherwise recommend and Makrod will place trades for those Clients according to the Clients’ instructions. D. Wrap Fee Programs Makrod does not participate in any wrap fee programs. E. Discretionary and Non-Discretionary Asset Management As of March 29, 2024, Makrod manages zero dollars on a discretionary basis and $780,166,820 on a non-discretionary basis.