General Information Gwynn Management Co (“Gwynn Management”) was formed in 1990, and provides portfolio management services to its clients. Nowland B. Gwynn II and David Fields are the principal owners of Gwynn Management. Please see Brochure Supplement(s), Exhibit A, for more information on the individuals who formulate investment advice and have direct contact with clients or have discretionary authority over client accounts. As of December 31, 2022, Gwynn Management managed $262,453,168 on a discretionary basis and no assets on a non‐discretionary basis. SERVICES PROVIDED At the outset of each client relationship, Gwynn Management spends time with the client, asking questions, discussing the client’s investment experience and financial circumstances, and reviewing options for the client. Based on its reviews, Gwynn Management generally develops a customized Investment Policy Statement (“IPS”) with each client. This document is designed to suit the client’s individual needs and includes, without limitation:
• Determination of an appropriate asset mix
• Criteria for the selection of no‐load mutual funds as equity vehicles and the level of participation they have in the equity portfolio
• Criteria for the purchase of exchange traded funds (ETFs) and individual stocks and the level of participation they have in the portfolio
• Criteria for the purchase of appropriate taxable or tax‐exempt bonds based on an agreed upon staggered maturity schedule; and
• Criteria for inclusion of bond funds, if appropriate The IPS is crafted by Gwynn Management in conjunction with the client and serves as a blueprint for the management of the portfolio.

Portfolio Management As described above, at the beginning of a client relationship, Gwynn Management meets with the client, gathers information, and performs research and analysis as necessary to develop the client’s IPS. The IPS will be updated from time to time when requested by the client, or when determined to be necessary or advisable by Gwynn Management based on updates to the client’s financial or other circumstances. To implement the client’s IPS, Gwynn Management will manage the client’s investment portfolio on a discretionary basis. As a discretionary investment adviser, Gwynn Management will have the authority to supervise and direct the portfolio without prior consultation with the client. Notwithstanding the foregoing, clients may impose certain written restrictions on Gwynn Management in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client’s investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client’s account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ, and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of Gwynn Management.