Firm Description Genter Capital Management ("Genter or Genter Capital") was originally founded in 1968 for the express purpose of managing investments using the common stocks of large and medium capitalized corporations, government fixed income, and investment grade corporate and municipal fixed income. The firm is a Registered Investment Adviser under the Investment Advisers Act of 1940 and has been continuously and actively engaged in the investment management business since its inception. Principal Owners Genter Capital is 100% owned by Genter Capital LLC. Mr. Daniel J. Genter is the principal owner of Genter Capital LLC. Types of Advisory Services Genter Capital furnishes “investment supervisory services,” defined as the giving of continuous advice to clients about the investment of funds on the basis of each client’s individual needs and objectives. Genter Capital acts as investment adviser to the Genter Capital Dividend Income Fund (GDIIX). Genter Capital offers a broad range of portfolio strategies ranging from equity to a variety of fixed income products, to include municipal bonds. These styles are designed to meet the risk profiles of our many clients. Client may impose restrictions on the portfolios managed by Genter Capital; please refer to the section entitled Investment Discretion for more information. Genter Capital has also established arrangements where it acts as a sub-advisor on certain accounts or provides model portfolio recommendations to other investment advisers. Services and fees for these arrangements will be negotiated. Wrap Fee Program Genter Capital participates

in certain programs where a client enters into an agreement with Genter Capital and a registered broker/dealer either directly or indirectly through an affiliate. The client is charged a combined fee (referred to as a “wrap fee”) based upon a percentage of the market value of the account, which generally covers all services for: 1) selection of program; 2) the investment advisers’ fee to manage the client’s portfolio on a fully discretionary basis; 3) brokerage commissions and, in some instances, dealer mark-ups or mark-downs for the execution of trades by the designated broker; 4) acting as custodian for the assets in the client’s portfolio which also includes providing the client with trade confirmations and monthly statements; 5) periodic evaluation and comparison of account performance; and 6) continuing consultations on investment objectives. However, there are some programs where some of these fees are not covered but are charged separately. Genter Capital receives a portion of this “wrap fee” for providing investment supervisory services. In some cases, Genter Capital’s advisory fee is a separate fee. For Fixed Income accounts, all wrap accounts are traded with non-wrap accounts; please refer to the section entitled Order Aggregation for information on blocking transactions. For Equity accounts, wrap accounts are traded on a rotational basis with non-wrap accounts. Assets Under Management As of December 31, 2023, Genter Capital has a total of $6.2 billion of assets under management, including $2.0 billion of model portfolio assets not included on the Firm’s ADV Part 1.