The firm’s advisory business was founded in 1984. Oppenheimer + Close, LLC, a Delaware limited liability company (“Oppenheimer + Close”), is a registered investment adviser. Oppvest LLC, a Delaware limited liability company (“Oppvest”), is an affiliated registered investment adviser owned and managed by the owners and managers of Oppenheimer + Close. Prior to September 2013 the firm’s business was conducted through Oppenheimer + Close, Inc., a New York corporation. The firm’s principal owner is Carl K. Oppenheimer. Advisory services for individually managed accounts Our focus is on “value” investing, and our horizon is long term. The majority of our research is conducted internally. Our primary focus is on exchange-listed or over-the- counter equity securities, both domestic and foreign. We use insured bank deposits and short-term Treasury issues for uninvested reserves. While we have not done so recently, we are not precluded from investing in warrants, corporate debt, municipal securities, exchange-traded funds, or money market funds if we perceive opportunity for profit at appropriate risk. We meet with and speak to clients regularly, and portfolios are tailored to the needs of individual clients. In general, clients will have the same portfolio holdings. Weightings may vary based on liquidity needs, timing of purchase, or other factors including risk tolerance and investment objectives. We generally attempt to accommodate investment restrictions imposed by clients (for example: an aversion to tobacco or casino companies). We obtain certain information from clients to determine financial condition and investment objectives. In the process of obtaining the information, we may provide ancillary financial planning and consultative services including asset allocation, risk management and income planning. Such financial planning and consultative services are intended to better design an investment portfolio consistent with long-term needs and goals. Clients are responsible for notifying us of any updates regarding financial situation, risk tolerance or investment objectives including modifications to existing investment restrictions; however we contact clients regularly to discuss any changes or updates that would alter investment objectives. Advisory Services for ERISA plans We provide an additional service for accounts held away from our primary custodian. These are primarily 401(k) accounts, 403(b)s, and other assets through an arrangement with Pontera Solutions Inc. Clients who engage us to provide asset management services for their ERISA plan wish to have an investment manager select their investments from among the Plan’s available investment options and manage their accounts for them. When determining asset allocation in a participant’s account we consider the participant’s investment options offered by the plan, retirement timeframe, life stages, risk tolerance and overall financial picture, including assets held outside the Plan. We strongly advise clients to review the Subscription Agreement, Terms & Conditions, and Privacy Policy of Pontera Advisors Solutions, Inc to understand the scope of contractual obligations. Retirement Plan Rollover Recommendations When Oppenheimer + Close provides investment advice regarding a retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (the “Code”), as applicable, which are laws governing retirement accounts. The way Oppenheimer + Close makes money creates some conflicts with the interest of clients, so Oppenheimer + Close operates under a special rule that requires us to act in such client’s best interest and not put our interest ahead of such client’s. Under this special rule’s provisions, Oppenheimer + Close must: 1) Meet a professional standard of care when making investment recommendations (give prudent advice); 2) Never put our financial interests ahead of clients when making recommendations (give loyal advice); 3) Avoid misleading statements about conflicts of interest, fees, and investments; 4) Follow policies and procedures designed to ensure that we give advice that is in the clients best interest; 5) Charge no more than is reasonable for our services; and 6) Give clients basic information about conflicts of interest. A conflict of interest arises when we make a rollover recommendation because it may result in compensation that we would not have received absent the recommendation. We can earn increased investment advisory

fees by recommending that clients roll over their account at the retirement plan to an IRA managed by Oppenheimer + Close and we will earn fewer investment advisory fees if clients do not roll over the funds in the retirement account. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in Oppenheimer + Close receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by Oppenheimer + Close and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to clients regarding a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of Oppenheimer + Close. Advisory services for pooled investment vehicles Oppvest manages three limited partnerships (two are hedged). Following is a brief description of each. P. Oppenheimer Investment Partnership, LP invests in undervalued securities and in securities issued by special-situation companies. Oppenheimer-Spence Financial Services Partnership, LP focuses its investment activities on publicly traded issuers in the financial services industry, including, but not limited to, banks, savings and loan associations, securities brokerage firms, mutual fund management companies, insurance companies, credit unions, mortgage origination and service companies. Oppenheimer-Close Investment Partnership, LP invests opportunistically without focusing on any particular industry or geographic region, but limits investment in the financial services industry to no more than 7.5% of assets at the time of purchase. There is the same 7.5% restriction for investments in non-public companies and alternative assets. Subadvisors P. Oppenheimer Investment Partnership has engaged SCSP Capital Advisors to manage a segregated account capped at $1,000,000 established for the sole purpose of acquiring shares of a specific security. SCSP Capital Advisors has the power to manage the account for the limited purpose of purchasing, selling, exchanging, converting, and entering into trades or otherwise effecting transactions in the shares on behalf of the P. Oppenheimer Investment Partnership, LP. Brokerage services With few exceptions, our clients, including the pooled investment vehicles we manage, use the brokerage services of Pershing Advisor Solutions LLC, an affiliate of The Bank of New York Mellon Corp. Pershing Advisor Solutions LLC is an introducing broker- dealer that clears its transactions on a fully disclosed basis through Pershing LLC, an affiliate of Pershing Advisor Solutions LLC. Pershing LLC also acts as qualified custodian. Clients with individually managed accounts may elect to have their assets held at Pershing LLC or at the custodian of their choice. Participation in Wrap Fee Programs A wrap-fee program is defined as any advisory program under which a specified fee or fees not based directly upon transactions in a client’s account is charged for investment advisory services (which include portfolio management and/or advice concerning the selection of other investment advisers) and the execution of client transactions. We do not offer or participate in wrap-fee programs. All our services are provided on a non- wrap fee basis which means fees and expenses for execution of client transactions charged by your broker/dealer and/or custodian are billed directly to the account separately from our advisory fees. We do not publish research reports or sell newsletters. We conduct no other business. As of December 31, 2023, our assets under management were $216,797,433, of which $213,152,674 were assets managed on a discretionary basis and $3,644,759 were assets managed on a non-discretionary basis.