A. Business Description: Westwind Capital (“WWC”) is a registered investment advisor. Originally incorporated in 1992 as Lord, Spence & Associates, the business was formerly a partnership between Roger Lord and James Spence. In 2000, James Spence and Kristi Spence became sole owners and changed the business’ name to Spence Asset Management. Eric Walton and Sheila Walton, both long-time employees, became co-owners and managing partners in 2005. In 2015, Eric Walton became majority owner of the firm and in 2018, Scott Kozney and Patrick Grooms became minority owners. In 2024, the business’ name became Westwind Capital. Eric Walton is still the majority owner, with James Spence, Scott Kozney and Patrick Grooms as minority owners. The firm’s website is www.ww-capital.com. B. Advisory Services Offered: WWC offers asset management services to individuals and institutions through WWC’s FOCUS Program. The Focus Program offers four primary disciplines described in detail in Item 8, Page 7. WWC implements a disciplined approach with a long-term orientation based on the clients’ unique circumstances. WWC believes in paying fair prices for extraordinary investments and staying focused on investment principles regardless of short- term market fluctuations. WWC also offers financial planning services to clients. These services are intended to assist clients seeking (i) generalized investment “education” and assistance in guiding investment decisions, (ii) specific investment “advice” and recommendations regarding investments and (iii) preparation of a financial plan designed to assist clients in identifying specific long-term financial objectives and needs. The services are not exclusive and may involve the provision of asset management in conjunction with preparation of a financial plan depending upon the arrangement discussed between the client and the advisor. WWC may also provide these services to retirement plans and plan participants. WWC’s financial planning services present a possible conflict of interest in that Patrick Grooms, CFP® and Scott Lieberwirth, CFP® are compensated based on assets managed in the firm’s FOCUS programs and they may recommend the firm’s FOCUS programs if they feel they fit a client’s investment objectives. Financial planning clients are not required to use WWC’s FOCUS 5 programs to pursue their investment objectives as there are other firms and organizations likely capable of providing similar services which they are free to select. On August 1st, 2022, WWC entered into a management agreement with the Private Fund and Spence Asset Management Holdings GP I, LLC, a Delaware limited liability company and the general partner to the Private Fund (the “General Partner”), pursuant to which WWC provides investment

advisory services to the Private Fund. The Private Fund was formed by Eric Walton, Scott Kozney and Sheila Walton in 2022. Those individuals own 100% of the General Partner. The investment objective of the Private Fund is to provide investors with attractive risk-adjusted returns by employing a successful investment philosophy to make strategic equity, debt, and real estate investments in the United States’ markets through direct and indirect investments in private entities, real estate, and other income producing assets with strong cash flow characteristics. The Private Fund intends to make investments in select opportunities to primarily create long-term capital appreciation and secondarily to produce current income in a tax-advantaged structure for the investors in the Private Fund. Pursuant to the management agreement, WWC shares responsibility to manage and control the business affairs of the Private Fund with the General Partner, as directed by the General Partner. WWC has authority to recommend investment decisions to the General Partner on behalf of the Private Fund. Only the General Partner will have authority with respect to the Private Fund’s investment decisions. The Private Fund presents a possible conflict of interest in that the General Partner is compensated through a 20% carried interest after full return of capital to the limited partners of the Private Fund, plus an 8% hardhurdle preferred return, and the owners of the General Partner (Eric Walton, Scott Kozney and Sheila Walton) may recommend that clients of WWC invest in the Private Fund if they feel it fits a client’s investment objectives. C. Client Tailored Services: Investment advisory services encompass developing active investment strategies for clients, taking into consideration their financial capacity, investment experience, investment objectives, and risk tolerance. Clients may impose reasonable restrictions on their investments including but not limited to: specific securities, types of securities, tax considerations, religious restrictions, and liquidity considerations. Investments for the Private Fund are managed in accordance with the Private Fund’s strategy, investment objectives, restrictions and guidelines and are not tailored to the individualized needs of any particular investor in the Private Fund. Information about the Private Fund can be found in its offering documents, including its private placement memorandum and its limited partnership agreement, which are made available to qualified investors in accordance with applicable securities laws. D. Wrap Fee Programs: We do not participate in WRAP fee programs or manage WRAP fee accounts. E. Assets Under Management: As of December 31, 2023: Total Discretionary Assets Managed $ 615,366,086 6 Total Non-Discretionary Assets Managed $ 5,717,388 Total Assets Under Management $ 621,083,474