Tom Johnson Investment Management, Inc., was founded in 1983 and is based in Oklahoma City, Oklahoma. Prior to the firm’s formation, several of the investment and administrative staff worked together at an Oklahoma bank’s Trust Department. In 1992 the firm's principals sold the company to United Asset Management (UAM). In 2000, UAM was acquired by Old Mutual, plc. In April of 2003, one of the principals, Richard H. Parry, bought back the company. In 2010, the firm was reorganized from a corporation to an LLC for tax purposes. Tom Johnson Investment Management, LLC (TJIM), is a registered Oklahoma Limited Liability Company. Investment Services TJIM offers investment services to a broad range of clients, such as pension, profit sharing and 401(K) plans, individual taxable, individual retirement accounts (IRA), foundations, banks, insurance companies, public funds, corporations, and sovereign funds. TJIM is a fee-only advisor with a fiduciary duty to provide prudent investment advice to its clients. TJIM does not accept fees or compensation based on product sales. TJIM does not have custody or possession of securities or cash of any client. Clients use institutions such as banks and brokerage firms to perform the custodial duties. The client grants TJIM permission to trade in their custodial account. This provides control between the client, custodian, and investment manager to safeguard the client’s assets. Clients who are not associated with a broker/advisor may give TJIM authority regarding client directed withdrawal instructions to their custodian for a distribution to a third-party account. Such authority requires a documented standing letter of instruction signed by the client. This “transaction account” is subject to all the rules of SEC Regulation S-ID. TJIM is responsible for decisions and recommendations as to asset allocation and security selection. TJIM may also be responsible for executing transactions and reviewing the results with the custodian. In addition, TJIM may provide risk tolerance determination, diversification, asset allocation, and mutual fund selection services for a fee to clients. In such cases, separate account management may not be advisable for some of the client’s accounts given unique characteristics or issues such as asset size, or inherited low cost-basis assets that already exist in the portfolio. TJIM provides investment management services through 4 different channels. The chart below is a general summary of the differences and description of each channel. TJIM Investment Management Services to Client by Channel Services Investment Advisory and Management Investment Management in a Wrap-Fee Program Investment Management as a Sub Advisor to a Sponsor Program Investment Model Programs TJIM Contract Signed ByClientClientSponsor Program Sponsor Program Portfolio Management Responsibility TJIMTJIMTJIMTJIM Model Trade Execution ResponsibilityTJIMTJIMTJIMSponsor Program Client Reporting & Performance Measurement TJIMTJIMSponsor Program Sponsor Program TJIM Investment FeeDirect to Client Direct or may be embedded in program fee Embedded in program fee Embedded in program fee TJIM Participation in “Wrap-Fee” Programs TJIM participates in wrap-fee programs on both an advisor and sub-advisor basis. TJIM’s management of accounts in these programs is the same as the management of an account not in a wrap- fee program. The wrap-fee charged by a program may include a portion that is paid to TJIM for our investment management services. Wrap-fee charges may include such other services as: investment management, consulting, trade execution, performance measurement, client reporting and custody. TJIM Participation in Model Portfolio Programs TJIM has contractual agreements to provide model portfolios for use in sponsors’ sub-advised programs. TJIM does not have individual account management responsibilities. These sponsors are responsible for determining account suitability, trade discretion and executions and for Form 13F filings. TJIM is compensated by the sponsors according to assets in the TJIM model portfolios. Investment Services to Meet the Needs of Clients Clients, with the assistance of TJIM or financial advisor, should determine their asset allocation based on:
• income and growth requirements  time horizon
• risk tolerance  tax implications
• unique circumstances • liquidity needs Based on the above considerations, clients give TJIM asset allocation parameters to manage portfolios. Additional client requested guidelines may

also be required in the management of a specific portfolio. Examples of these are coordination with other assets, quality ratings, issuer size, issue size, yield, exclusion of certain types of business or products. Portfolios under TJIM care, whether they are equity, balanced or fixed, are managed by a team. The accompanying chart illustrates this investment process. Four Step Process 4. Review Process 1. Identify Objectives 3. Investment Evaluation & Selection 2. Strategy/Asset Allocation For control purposes, our investment compliance committee reviews with frequency investment performance, asset allocation, trades to implement model changes, quality ratings, security level deviation from model holdings and account restrictions to ensure compliance with client and TJIM guidelines. Portfolio managers, when reviewing client accounts under their care, consider such matters as:
• Is the portfolio structured to meet the investment objective?
• Is the investment objective still suitable for the client?
• Are the policies and procedures of the client being followed? While accounts adhering to a specific style or model are managed to be homogenous, they may vary in individual holdings and weights due to deposit or withdrawal timing, tax implications, individual account restrictions, inherited positions, account size or rounding. TJIM Additional Services Financial Planning TJIM assists some clients with financial planning services, which can include the following:
• Current situation assessment and needs analysis with Client Relationship Summary (CRS) disclosure
• Department of Labor (DoL) Fiduciary acknowledgement when providing investment advice to retirement investors with a SWOT analysis of potential IRA rollovers
• Asset allocation planning
• Tax planning
• Efficient gifting
• Social Security planning
• Efficient retirement distribution strategies
• Income planning and budgeting Reporting Services TJIM offers reporting services for those clients who want to supervise and direct their own portfolios but do not have the resources to maintain the data. Our reporting capability provides information:
• To assess investment characteristics • For tax reporting
• To address documentation and control Portfolio Reporting Portfolio reporting provides annual, quarterly and/or monthly information. Reports include:
• Realized gain/loss • Transaction history
• Tax lots • Investment performance Portfolio composition capable of being sorted alphabetically, by industry, market value, unrealized appreciation and/or yield Fixed Income Portfolio Analysis For fixed income investors, a unique analysis for examining the investor’s holdings and risk level is provided. This may be particularly useful for those who maintain custody accounts with a variety of institutions. Reports contain individual securities and aggregate portfolio statistics as well as the range and structure of such key fixed income variables as:
• Duration • Maturity
• Quality • Yield
• Cash flow • Taxability
• Callability • Diversification Such a report enables an investor to assess risk and return on a security level and on an aggregate basis. TJIM Portfolio Managers are available to meet with clients to explain the reports, make portfolio suggestions, and to address questions. TJIM Assets Under Management As of 12/31/2023, TJIM’s Regulatory Assets under Management: $1,505,566,999 The TJIM Regulatory Assets Under Management (AUM) amount identified above is calculated according to SEC Form ADV instructions for Item 5.F: “Calculating Your Regulatory Assets Under Management”. Item 5.F. defines Regulatory Assets Under Management to include “securities portfolios for which you provide continuous and regular supervisory or management services”, therefore we include all accounts for which we have access to the underlying portfolio of securities, and we build the trades for the specific account. We do not include accounts for which we do not build the trades for the account but rather set a “model” target percentage position and the underlying account is not monitored by TJIM. This creates a distinction where some Unified Managed Accounts (UMA) are included in AUM and others are excluded. We exclude UMA portfolios where we do not monitor the underlying portfolio, and we include UMA portfolios where we monitor and trade the underlying portfolios. Assets Under Supervision (UMA equity model) $13,965,771