Capital Consulting & Asset Management (hereinafter referred to as “CCAM”) is an investment advisor firm registered with the Securities and Exchange Commission (“SEC”) offering a variety of advisory services customized to your individual needs. A. CCAM was established in May of 1996. CCAM is wholly owned by Robert E. Nixon and Amber Roemer. B. CCAM offers the following advisory services. Each of the services is more fully described below.  Financial Planning and Consulting  Portfolio Manager Evaluation, Selection, Due Diligence and Monitoring  Privately Managed Portfolio Program  Qualified Plan Consulting Services & Fiduciary Services C. CCAM tailors the advisory services it offers to your individual needs. You may impose restrictions and/or limitations on the investing in certain securities or types of securities. CCAM will ask you to complete a client profile form to assist CCAM with obtaining information about your financial situation and history. Additionally, CCAM will meet with you and conduct an interview and data gathering session to continue the due diligence process. You should expect one to three meetings before implementation of recommendations begins (both in person and via phone conference). The information gathered by CCAM will assist CCAM to provide you with the requested services and customize the services to your financial situation. Depending on the services you have requested, CCAM will gather various financial information and history from you including, but not limited to:  Retirement and financial goals  Attitudes toward risk  Investment objectives  Investment horizon  Financial needs  Cash flow analysis  Cost of living needs  Education needs  Savings tendencies  Other applicable financial information required by CCAM in order to provide the investment advisory services requested D. CCAM does not participate in a wrap fee program in which CCAM provides portfolio management services. E. As of December 31, 2023 we have $196 million of client assets under our discretionary management. We provide consulting on approximately $100 million non-discretionary client assets. 5 of 28 Privately Managed Portfolio Program (“PMP”) The PMP Program provides individual portfolio management for an all-inclusive fee. The Privately Managed Portfolio Program (“PMP”) offers individually managed investment accounts to clients, for clients with more than $500,000 of assets under management, providing access to the investment advisory services of a select, prescreened group of investment advisers (investment managers). CCAM, through the PMP Program, helps investors select appropriate advisor/money managers to manage their portfolio, pays the manager's investment advisory fee on behalf of the investor, monitors and evaluates the manager's performance, executes the investor's portfolio transactions without commission charge, and provides custodial services for the investor's assets, or provides any combination of these or other services, all for a single fee all-inclusive fee paid by the investor to CCAM. The program also provides for on-going consulting services, account monitoring and performance reporting. Portfolio composition will be determined based on each client's needs and portfolio restrictions, if any, the client's financial goals, age and risk tolerances. CCAM has created various model portfolios: The portion of the portfolio under direct management by CCAM will be managed based on one of CCAM’s model portfolios. Your managed account may be similarly managed and contain similar holdings as compared to other clients’ managed accounts. Should CCAM make a change to its model portfolios, the change will be implemented across all clients’ accounts participating in the model portfolio regardless of taxable gains or losses. Typically when a client has under $500,000 of assets under management, CCAM will itself manage the client's portfolio. In this instance, CCAM will design and continuously manage a portfolio consisting entirely of mutual funds (primarily, though not necessarily exclusively, of no-load mutual funds) with the goal of meeting each client's individual needs. The PMP program offers advice regarding equity securities, warrants, corporate debt, commercial paper, bank certificates of deposit, municipal securities, investment company securities, U.S. government securities, options and futures contracts and partnerships, including real estate, equipment leasing and mortgage leasing. Some strategies, such as with option contracts, involve more risk and are only appropriate for certain investors. In selecting independent money managers, CCAM will use an asset allocation strategy, recommending one or more managers in the following investment styles: 1. Large Cap Growth 2. Large Cap Value 3. Mid Cap Growth 4. Mid Cap Value 5. Small Cap Growth 6. Small Cap Value 7. Infrastructure 8. Small/Mid Technology Growth 9. International Growth 10. International Value 11. International Emerging Markets 12. Taxable Fixed Income 13. Tax Exempt Fixed Income 14. Fixed Income: Insurance Company GIC/SPDA 15. Fixed Income: High Yield Bonds 16. Fixed Income: Real Estate: REITs 17. Fixed Income: Convertible Bonds 18. Fixed Income: TIPS (Treasury Inflation Protected Securities) 19. Fixed Income Adjustable Rate Governments 20. Fixed Income High Dividend Paying Securities 6 of 28 CCAM will assist the client in determining which portion of his or her assets should be allocated among these investment styles and will recommend appropriate managers within each style. Selection of Money Manager for Clients Based on CCAM's understanding of the client’s investment needs and objectives, CCAM will recommend one or more investment managers from those participating in the program whose investment philosophy and objectives CCAM believes are most compatible with the client’s investment philosophy and objectives. Both CCAM and client-chosen investment managers have discretionary authority. Clients are advised that an investment manager’s past performance is not a guarantee of future results. Certain market and economic risks exist that may adversely affect a manager’s performance which could result in capital losses in that client’s account. The selection of risk parameters and comparative indices by CCAM with which to compare a client’s account performance are for informational purposes only. No guarantee is expressed or implied that the client’s account performance will compare favorably to such parameters or indices. CCAM will continuously monitor the investments made for each client account being managed by one or more money managers. During this part of the process CCAM monitors the managers and investments selected by the client. In situations where CCAM believes that a recommended money manager is not meeting the client's goals, CCAM may recommend the use of another money manager. Additionally, CCAM will recommend a replacement of a manager if CCAM believes the manager is not adhering to stated management style or objectives, has a material change in the professional staff, unexplained poor performance, or inconsistencies among accounts managed by the same manager. You are advised transactions in the account, account reallocations and rebalancing may trigger a taxable event, with the exception of IRA accounts, 403(b) accounts and other qualified retirement accounts. Qualified Plan Consulting, Fiduciary Services & Fiduciary Management Services CCAM provides qualified plan committees with the following Fiduciary Retirement Plan Consulting Services:  Investment Policy Statement. CCAM will help the retirement plan client develop an investment policy statement. The investment policy statement establishes the investment policies and objectives for the Plan. The retirement plan client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement.  Investment Selection Services. CCAM will provide the retirement plan client with recommendations of investment options consistent with ERISA section 404(c).  Due Diligence Review. Upon request, CCAM will provide retirement plan client with periodic due diligence reviews of the Plan, the Plan’s fees and expenses, and the Plan’s portfolio managers.  Investment Monitoring. Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund 7 of 28 management and conformation to the guidelines set forth in the investment policy statement and make recommendations to maintain or remove and replace investment options.  Qualified Plan Development. If needed, CCAM will assist a retirement plan client with the establishment of a qualified plan by working with the retirement plan and a selected Third Party Administrator. If the retirement plan client has not already selected a Third Party Administrator, CCAM will assist the retirement plan client with the review and selection of a Third Party Administrator for the retirement plan.  Participant Educational Presentations. CCAM will provide educational presentations for Plan participants. Presentations to the retirement plan participants are informational in nature and intended to provide an overview of the retirement plan and the plan’s investment options. Educational presentations will not take into account the individual circumstances of each participant and individual recommendations will not be provided unless otherwise agreed upon.  Participant Enrollment. CCAM will assist in the group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. During the course of the annual service cycle, it is understood that CCAM may not in any given year perform each of the above services, as some services are offered on an as-needed basis. It is understood that CCAM will be entitled to the full annual service fee regardless of whether all Plan consulting services are needed on an annual basis. CCAM also offers retirement plans with Fiduciary Management Services. If a retirement plan engages CCAM for Fiduciary Management Services, the retirement plan client will appoint CCAM as its investment adviser of record of the retirement plan. The retirement plan’s Account will consist only of separate account(s) held by qualified custodian(s) under the name of the retirement plan client. The qualified custodian(s) will maintain physical custody of all funds and securities of the retirement plan client, and the retirement plan client will retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the retirement plan. The retirement plan client’s beneficial interest in a security does not represent an undivided interest in all the securities held by the qualified custodian(s), but rather represents a direct and beneficial interest in the securities which comprise the Account. At least quarterly, the retirement plan or retirement plan participants will receive an account statement from the qualified custodian or the Third- Party Administrator to the retirement plan detailing transactions in the Account. Upon appointment as an investment adviser of the Account, CCAM will obtain from the retirement plan client information to determine the retirement plan’s financial situation, investment objectives and risk tolerance. If an investment policy statement does not exist, a specific investment strategy and investment policy will be crafted for the retirement plan client that focuses on the retirement plan’s specific goals and objectives. As described below, the retirement plan may impose reasonable restrictions upon CCAM’s management of the Account’s securities, including the ability to instruct CCAM not to purchase certain securities on behalf of the Account. The Account will be managed by CCAM, in accordance with the instructions listed below, on the basis of the retirement plan’s investment policy statement.

The retirement plan will timely notify CCAM of any changes to the retirement plan’s financial situation or investment objectives or if the retirement plan wants to impose and/or modify any 8 of 28 reasonable restrictions on the management of the Account. At least annually, CCAM will contact the retirement plan to determine whether the plan’s financial situation, investment objectives or risk tolerance have changed, or if the plan wants to impose and/or modify any reasonable restrictions on the management of the Account. CCAM will be reasonably available to consult with retirement plan relative to the status of the Account. Under the Fiduciary Management Services, CCAM will provide a retirement plan client with continuous and ongoing supervision over the designated retirement plan assets. CCAM will actively monitor the designated retirement plan assets and provide advice to retirement plan client regarding buying, selling, reinvesting or holding securities, cash or other investments of the retirement plan. In order for CCAM to provide Fiduciary Management Services, the retirement plan client grants CCAM discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for the designated retirement plan assets in the sole discretion of CCAM without first consulting with the retirement plan or its participants. The retirement plan client also grants CCAM the power and authority to carry out these decisions by giving instructions, on behalf of retirement plan, to brokers and dealers and the qualified custodian(s) of the retirement plan for CCAM’s management of the designated retirement plan assets. If a retirement plan client has elected to utilize CCAM’s Fiduciary Management Services, then CCAM will be acting as an Investment Manager to the Plan, as defined by ERISA section 3(38), with respect to the management of the retirement plan’s assets subject to investment discretion, and CCAM acknowledges that it is a fiduciary with respect to its exercise of discretion. CCAM acknowledges that Fiduciary Management and Fiduciary Consulting services constitute investment advice to a retirement plan for compensation and, as a consequence, CCAM is deemed a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) when providing such services. CCAM will act in a manner consistent with the requirements of a fiduciary under ERISA for all services for which CCAM is considered a fiduciary under ERISA. If the retirement plan has elected to receive only Fiduciary Consulting Services and no Fiduciary Management Services, then the parties acknowledge and agree that CCAM (a) has no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting management of client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of client’s retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of client’s retirement plan or the interpretation of client’s retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of client’s retirement plan as defined in ERISA. If a retirement plan client has elected to receive any Fiduciary Management Services, then CCAM will be acting as an Investment Manager to the retirement plan as defined by ERISA section 3(38). CCAM will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c), to you any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclose as soon as practicable). 9 of 28 In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Consulting Agreement and any compensation or fees received in connection with the Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learn of such error or omission. The exact suite of services provided to a retirement plan client will be listed and detailed in the Qualified Retirement Plan Consulting Agreement. In addition to the above Qualified Plan consulting services, CCAM and other vendors will provide qualified plan clients with the following services:  Custom designed or prototype plan documents available through our strategic alliances  Find a custodian  Provide access to a broad selection of quality investment options, including access to over 11,000 mutual funds, ETF’s, and separate accounts  Offer access to all NTF mutual funds without any commissions, front end, or back end fees  Offer access to all individual securities transactions at institutional discounted rates  Offer comprehensive recordkeeping and administration with daily or balance forward valuation methods  Provide Albridge Solutions portfolio management system reports  Provide consolidated monthly statements detailing all transactions and asset positions  Provide consolidated yearly statements detailing all transactions and asset positions Financial Planning and Consulting Services CCAM provides specific consultation and administrative services regarding investment and financial concerns of the client. Clients can also receive investment advice on specific area(s) of concern such as education planning, estate planning, retirement planning, or any other specific topic. Additionally, CCAM provides advice on non-securities matters. Generally, this is in connection with the rendering of estate planning, insurance, and/or annuity advice. This may include the recommendation of so called no-load life insurance products to clients for whom these may be appropriate investments. Financial plan recommendations are not limited to any specific product or service offered by a broker dealer or insurance company. Clients obtaining financial planning services will be provided a written financial plan with recommendations and actions to assist the client to work toward their stated financial goals and 10 of 28 objectives. In general, the financial plan will address one or more of the following areas of concern: PERSONAL: Family records, budgeting, personal liability, estate information and financial goals. TAX & CASH FLOW: Income tax and spending analysis and planning for past, current and future years. We will illustrate the impact of various investments on your current income tax and future tax liability. DEATH & DISABILITY: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis. EDUCATION OF CHILDREN: Evaluation of assets needed to provide post-secondary education. RETIREMENT: Analysis of current strategies and investment plans to help the client achieve his or her goals. ESTATE PLANNING: Analysis of current situation and strategies to help the client achieve his or her goals. INVESTMENTS: Analysis of investment alternatives and their effect on a client’s portfolio. Planning and consulting services are based on your financial situation at the time and are based on financial information disclosed by you to CCAM. You are advised that certain assumptions may be made with respect to interest and inflation rates and use of past trends and performance of the market and economy. However, past performance is in no way an indication of future performance. CCAM cannot offer any guarantees or promises that your financial goals and objectives will be met. Further, you must continue to review the plan and update the plan based upon changes in your financial situation, goals, or objectives or changes in the economy. Should your financial situation or investment goals or objectives change, you must notify CCAM promptly of the changes. You are advised that the advice offered by CCAM may be limited and is not meant to be comprehensive. Therefore, you may need to seek the services of other professionals such as an insurance adviser, attorney and/or accountant. You are not obligated to implement advice through CCAM or Advisory Representatives. Should you implement the plan with CCAM’s Advisory Representatives, commissions or other compensation may be received in addition to the advisory fee paid to CCAM. Invest RX – A Digital Advisor Through the Invest RX – A Digital Advisor program, CCAM offers asset management services to individuals through an online digital platform. When managing assets in this Program, CCAM will utilize discretionary portfolio models created by CCAM. Upon appointment as an investment adviser of the Account and enrollment of Client into the Program, CCAM will use a digital platform with automated questions to obtain from Client information to determine Client’s financial situation, investment objectives and risk tolerance. A specific investment strategy and investment policy is crafted for Client and focuses on Client’s specific goals and objectives based upon the information disclosed by Client via the digital platform. CCAM will then recommend via the digital platform an appropriate investment and risk profile (“Profile”) based upon the information Client has provided during the online enrollment process. CCAM will actively monitor the Account and make decisions regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account. 11 of 28 CCAM’s models are generally limited to ETFs, mutual funds, money markets and cash and will not typically involve other securities such as individual stocks or bonds. In addition to the above-described asset management services, clients will receive access to a digital platform for clients to monitor their performance, automated account rebalancing, certain digital financial planning tools (e.g., e-Money Advisors), and email and phone communications with CCAM. Through the digital platform, Client will timely notify CCAM of any changes to Client’s financial situation or investment objectives. CCAM has appointed certain investment adviser representatives (“IARs”) which will be reasonably available to consult (via telephone or online) with Client relative to the status of the Account. Client understands that the asset management services provided under the Invest RX program do not include financial planning, consulting or any other similar services, including in-person consulting with an investment advisor representative of CCAM. Client must execute a separate agreement for other services of CCAM. In this digital offering, clients do not receive annual reviews or quarterly performance statements from CCAM. However, Clients can, for an additional hourly fee, receive in-person financial planning advice and other comprehensive planning services offered to non-automated clients. General Information You are advised the investment recommendations and advice offered by CCAM are not legal advice or accounting advice. You should coordinate and discuss the impact of financial advice with your attorney and/or accountant. You are advised that it is necessary to inform CCAM promptly with respect to any changes in your financial situation and investment goals and objectives. Failure to notify CCAM of any such changes could result in investment recommendations and advice not meeting your needs.