Arbor Capital Management is an SEC-registered investment adviser with its principal place of business located in NY. Arbor Capital Management began conducting business in 1995. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).
• Lawrence Thomas McGowan, President
• Gerald Thomas Cole, Vice President & Chief Investment Officer Arbor Capital Management offers the following advisory services to our clients: INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides asset management of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on the client's particular circumstances are established, we develop the client's investment guidelines. We create and manage a portfolio based on these guidelines. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we will also review and discuss a client’s prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives and target asset allocation, as well as tax considerations. Clients may revise their investment guidelines by notifying our firm and signing the appropriate form. Clients can impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Once the client's portfolio has been established, we review the portfolio at least quarterly and rebalance the portfolio from time to time based on the client's individual needs. Tactical market considerations may cause us to materially adjust an asset allocation from time to time unless otherwise specified by the client in writing. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issues
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Mutual fund shares
• United States governmental securities
• Options contracts on securities
• Interests in partnerships investing in real estate
• Interests in partnerships investing in oil and gas interests Because some types of investments involve certain additional degrees of risk, they will only be implemented when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. We will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held in the client’s account(s), including, but not limited to, the filing of “Proofs of Claim” in class action settlements. If desired, clients may direct us to transmit copies of class action notices to a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to you. 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 interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• 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. Investors considering rolling over assets from a qualified employer-sponsored retirement plan (“Employer Plan”) to an Individual Retirement Account (“IRA”) should review and consider the advantages and disadvantages of an IRA rollover from their Employer Plan. A plan participant leaving an employer typically has four options (and may engage in a combination of these options): (1) Leave the money in the former employer’s plan, if permitted; (2) Rollover the assets to a new employer’s plan (if available and rollovers are permitted); (3) Rollover Employer Plan assets to an IRA; or, (4) Cash out the Employer Plan assets and pay the required taxes on the distribution. At a minimum, Investors should consider fees and expenses, investment options, services, penalty-free withdrawals, protection from creditors and legal judgments, required minimum distributions, and employer stock. We encourage you to discuss your options and review the above listed considerations with an accountant, third-party administrator, investment advisor to your Employer Plan (if available), or legal counsel, to the extent you consider necessary. We have an economic incentive to encourage investors to rollover Employer Plan assets into an IRA managed by us, as we will earn fees as a result. PENSION CONSULTING SERVICES We also provide several advisory services separately or in combination. While the primary clients for these services will be pension, profit sharing and 401(k) plans, we offer these services, where appropriate, to individuals and trusts, estates and charitable organizations. Pension Consulting Services are comprised of four distinct services. Clients may choose to use any or all of these services. Investment Policy Statement Preparation (hereinafter referred to as ''IPS''):

We will meet with the client (in person or over the telephone) to determine an appropriate investment strategy that reflects the plan sponsor's stated investment objectives for management of the overall plan. Our firm then prepares a written IPS detailing those needs and goals, including an encompassing policy under which these goals are to be achieved. The IPS also lists the criteria for selection of investment vehicles as well as the procedures and timing interval for monitoring of investment performance. The IPS is submitted to the client for approval. Selection of Investment Vehicles: We assist plan sponsors in constructing appropriate asset allocation models. We will then review various investments (both index and managed) to determine which investments are appropriate to implement the client's IPS. Monitoring of Investment Performance: We monitor client investments periodically, based on the procedures and timing intervals delineated in the Investment Policy Statement. We monitor the client's portfolio and will make purchases and sales or recommendations to the client as market factors and the client's needs dictate. Employee Communications: For pension, profit sharing and 401(k) plan clients with individual plan participants exercising control over assets in their own account (''self-directed plans''), we may also provide quarterly educational support and investment workshops designed for the plan participants. The nature of the topics to be covered will be determined by us and the client under the guidelines established in ERISA Section 404(c). The educational support and investment workshops will NOT provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations. CONSULTING SERVICES Clients can also receive investment advice on a more focused basis. In certain circumstances this includes advice on only an isolated area(s) of concern. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. Consulting recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a generic nature. Client can authorize and instruct us on a non-discretionary basis after consulting with us to purchase, sell, invest, exchange, convert, trade and any other transaction therein, securities for the Client's Account. If we have been provided by the client with written investment guidelines or policies same shall be incorporated herein and shall be exercised with reference to such written guidelines or policies. It is the Clients responsibility to advise the Advisor in writing of any changes or modifications to investment guidelines, policies or Clients financial circumstances therein. WRAP FEE ACCOUNT MANAGEMENT We also participate in several wrap fee programs by providing portfolio management to clients of those programs. A wrap fee program is a means of consolidating and managing an investor’s portfolio. The wrap fee services are offered for a comprehensive charge by an investment advisor to a client for providing a bundle of services. Such services include investment advice, brokerage and custodial services. This fee covers all of the administrative and management expenses for the account. Our firm receives a portion of the wrap fee for our services. SELECTION OF OTHER ADVISERS We offer non-discretionary advisory management services on a consulting basis by selecting and monitoring other investment managers. The client has fixed income assets as part of its capital reserves. The client’s IPS requires diversification of managers. The IPS is developed through discussions in which the client's goals and objectives are established based on the client's particular circumstances from time to time. The asset allocation strategy is drafted into the client's IPS. The client’s objective when selecting an outside manager is to provide additional investment exposure to supplement other investment management services. Arbor Capital Management performs management searches of various investment advisers. Based on the client’s circumstances and needs (as exhibited in the client's investment policy statement) we determine which selected registered investment adviser's ("selected asset manager") fixed income portfolio management style is appropriate for that client. Factors considered in making this determination include account size, risk tolerance and the investment philosophy of the selected asset manager. Once we identify an appropriately selected asset manager, our firm negotiates the manager fee for the advisory management services and provides the selected asset manager a portion of the client's portfolio based on that investment policy statement. The client may have more than one selected asset manager. On an ongoing basis, we monitor the fixed income distribution of each manager and of the clients consolidated portfolio including but limited to the following: current yield, average maturity, average coupon, average duration, average rating by Moody’s and S&P, market value, individual holdings of securities, annual expected Income, percentage of holdings in allowable asset sectors and performance of the selected asset manager(s). If we determine that a particular selected asset manager is not providing sufficient management services to the client, or is not managing the client's portfolio in a manner consistent with that client's investment policy statement, then we will recommend the client terminate the manager and we will perform a search for a replacement and transferred to a different selected asset manager. Under this scenario, our firm does not have the discretion to hire and fire the selected asset manager and/or move the client’s portfolio to a different selected asset manager. Discretion to hire and fire is based upon our recommendation to the clients Board of Directors. At least semi-annually, we meet with the client to review and update, as necessary, the client's IPS. However, should there be any material change in the client’s financial situation, the client should notify us immediately to determine whether any review and/or revision of the client's IPS is warranted. AMOUNT OF MANAGED ASSETS As of 12/31/2023, we were actively managing $402,908,163 of clients' assets on a discretionary basis plus $531,268,890 of clients' assets on a non-discretionary basis.