A. Firm Information McGowan & Co., LLP, a Pennsylvania limited liability company (“McGowan”) has been in business since 1997. The firm’s principal owners are Brian McGowan, Jr. and Brendan McGowan. B. Advisory Services Offered McGowan provides personalized investment management services. The firm provides financial advice to individuals, pension and profit sharing plans, trusts, estates, charitable organizations and businesses. Asset Management Asset management services involve the rendering of advice to clients regarding the purchase and sale of securities in the client’s account. Asset management services are typically provided on a “non-discretionary” basis. When McGowan is engaged to provide asset management services on a non-discretionary basis, McGowan will monitor the accounts to ensure that they are meeting the client’s asset allocation requirements. If any changes are needed, changes to the account will not be made until McGowan has confirmed with the client (either verbally or in writing) that the proposed change is acceptable to the client. These changes may involve selling a security or group of investments and buying others or keeping the proceeds in cash. Clients may at any time place restrictions on the way their account is managed. For example, a client may restrict the types of investments McGowan may use in the client’s account, or the allocations to a security type. It is important for clients to keep McGowan updated as to the

client’s contact information, and to respond quickly when contacted for trade permission. Otherwise, the client’s account may not be traded in an efficient and timely manner, which could adversely affect performance. In limited circumstances, a client may engage McGowan to provide investment management services on a discretionary basis. We monitor the accounts in the same way as for non-discretionary services. The difference is that if changes to the account are needed, McGowan will make the changes without the client’s prior authorization. Clients engaging McGowan on a discretionary basis will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) as well as an Investment Management Agreement that outlines the responsibilities of both the client and McGowan. When clients engage McGowan to provide asset management services, the client and McGowan will execute an Investment Management Agreement that describes the services to be provided, the fees for the service, other expenses related to the provision of the investment management services, and how to terminate the agreement. Wrap Program McGowan does not participate in or sponsor a wrap program. Assets under Management As of December 31, 2023, McGowan manages approximately a total of $485,010,799 in assets under management across 236 accounts. Of that total, $3,026,022 is managed on a discretionary basis, in 7 accounts.