A. Description of Advisory Firm Compton is an SEC-registered investment adviser, with its principal place of business located in Providence, Rhode Island. The Firm was incorporated on January 8, 1988 and began conducting business as a registered investment adviser in 1991. Compton is wholly owned by George F. Kilborn.Compton has entered into an Asset Purchase Agreement with MBI Investment Advisors Inc., d/b/a PensionmarkMeridien (“PensionmarkMeridien”),which has an Advisor Affiliation Agreement with Pensionmark Financial Group LLC (“Pensionmark”), to buy the assets, including clients, of the Firm. George Kilborn continues to provide investment advisory services to Compton’s remaining clients until they transfer to Pensionmark or until the accounts that elect not to utilize Pensionmark for investment advisory services are closed by Compton. The Firm is no longer accepting new clients or new client accounts. B. Types of Advisory Services At Compton, advisory services are tailored to the individual needs of clients. Goals and objectives are clarified in meetings and correspondence and are used to determine the course of action for each individual client. Through discussions with the client or a client representative, in which goals and objectives based upon a client's particular circumstances are established, we develop a client's investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s objectives, time horizons, risk tolerance and liquidity needs. We also review and discuss a client's prior investment history, as well as family composition and background, as appropriate. Compton offers investment management services on both a discretionary and non-discretionary basis, as agreed to with the client. We primarily manage portfolios for individuals, high net worth individuals, pension and profit-sharing plans (but not the plan participants), charitable organizations, and corporations. Account supervision is guided by the client's stated objectives (e.g., growth, income, growth and income, capital preservation), as

well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. These restrictions or limitations, along with additional details regarding services, fees, investor suitability standards and other specific terms applicable to clients, are set forth in the investment management agreement between the client and Compton. Our investment recommendations are not limited to any specific type of investment. Because some types of investments involve certain additional degrees of risk, they will be implemented or recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must:
• Meet a professional standard of care when making investment recommendations;
• Never put our financial interests ahead of yours when making recommendations;
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. For more information about our conflicts of interest, please review items 5, 10, 11 and 14 or reach out to us using the contact information on the cover page of this brochure. C. Amount of Managed Assets As of December 31, 2022, Compton managed $201.7 million of client assets on a discretionary basis. Compton Capital Management, Inc. – Form ADV – Page 5 of 14