Crown Capital Securities, L.P. (“Crown”), which is a SEC-registered investment adviser, is also a FINRA registered broker-dealer. Crown began conducting business in 1999 with its principal place of business located in Orange, California. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company):
• Mr. Darol K. Paulsen, CEO
• Delta Broker Holding, LLC, Shareholder Delta Broker Holding, LLC, is a Limited Partner of Delta Capital Holdings, LLC. The general partner, Delta Capital Holdings, LLC, is controlled by RET, LP, and the Paulsen Trust, collectively referred to as the "members". Crown provides investment advisory services to a variety of clients. Our investment advice is delivered through our investment adviser representatives (“Advisory Associates”) who are also registered as securities representatives of our broker-dealer. Advisory Associates provide advisory services on a non- discretionary or discretionary basis. Clients who select a non-discretionary agreement must be contacted by their Advisory Associate and give prior consent to any transactions. Clients with discretionary agreements have authorized their Advisory Associate to manage the account without prior consent for each transaction. Clients may impose limitations on discretionary agreements, if preferred. Crown currently manages $1,078,182,196 on a non-discretionary basis and $144,926,044 on a discretionary basis in its Advisory Programs as of 12/31/2022. Crown offers the following advisory services to our clients: Financial Planning Services Investment Supervisory Services Crown Heritage Program (Wrap Fee or Non-Wrap Managed Account Options) Crown Heritage Adviser Advantage Program (Wrap Fee Program) Crown Sterling Adviser Program (Wrap Fee or Non-Wrap Managed Account Options) Advisory Referral Services to various Third Party Asset Managers Financial Planning Services We provide financial planning services. The goal of financial planning is a comprehensive evaluation of a client's current and future financial state by using currently known variables to estimate future cash flows, asset values and withdrawal plans. Through the financial planning process, a wide range of questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients may purchase this service in one or more of the following ways: 1. Hourly Financial Planning consultation services 2. A written Financial Plan 3. An annual Financial Planning Service Agreement In general, the financial planning services can address any or all of the following areas: Crown Capital Securities, LP - IA firm brochure Page 5 of 34 03/31/2023 Personal: We review family records, budgeting, personal liability, estate information and financial goals. Tax & Cash Flow: We analyze the client's income tax and spending and planning for past, current and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability. Investments: We analyze investment alternatives and their effect on the client's portfolio. Insurance: We review existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile. Retirement: We analyze current strategies and investment plans to help the client achieve his or her retirement goals. Corporate Planning: We assist the client with formulating long term business goals, strategic planning, performance metrics, executive compensation plans and employee benefits. Death & Disability: We review the client's cash needs at death, income needs of surviving dependents, estate planning and disability income. Estate: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law. Real Estate: Advisory Associates with appropriate background, experience, and licenses in real estate may provide assistance with the valuation, structuring and disposition of real property. Advisory Associates in their separate capacity(ies), are able to offer these real estate services to advisory clients for separate and typical compensation (i.e., commissions, or other sales-related forms of compensation). These services are considered an outside business activity and are not offered by Crown. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. It is possible that recommendations made to any one client may be contrary to or exactly the opposite of recommendations made to other clients because many different Advisory Associates in different locations will be making investment recommendations to clients. The recommendations provided in any of the following “Financial Planning Services” will be valid as of the date(s) provided and will not be valid for any period beyond that (those) date(s). Hourly Financial Planning consultation services: Clients can receive financial planning advice on a more focused basis for an hourly fee. This may include advice on only an isolated area(s) of concern such as specific investments, estate planning, retirement planning, or any other specific topic. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. A written Financial Plan: We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client and prepare a written report. Should the client choose to implement the recommendations Crown Capital Securities, LP - IA firm brochure Page 6 of 34 03/31/2023 contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client's discretion. This service may also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. The client will agree to the scope and depth of each financial plan in advance. In addition, all fees, deliverables and timeline will be determined in advance and presented to the client. Written financial plans will be delivered to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. An annual Financial Planning Service Agreement: Over the course of a twelve (12) month period, we gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client and prepare an initial written financial analysis. We will update the analysis periodically as requested by the client. In addition, we provide consultation services throughout the course of the agreement upon the client's request. As appropriate, we may make recommendations to the client throughout the engagement based on the criteria above. Should the client choose to implement the recommendations made, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan or investment recommendations is entirely at the client's discretion. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. The client and the Adviser Representative will collectively agree to the scope and depth of each annual financial planning service engagement in advance. In addition, all fees, deliverables and timeline will be determined in advance of signing the agreements. Additional costs and conflicts of interest when implementing the Plan or Agreement Should the client elect to work with the Crown adviser to implement some or all of the recommendations offered in the Plan or Agreement, there will be additional costs to execute the advice. These costs could be in the form of advisory fees, commissions, and/or other transaction or investment- related expenses that will vary depending upon the type of investment(s) selected, and whether your dually-licensed Adviser is acting in the capacity of Adviser or Registered Representative. Clients should review the prospectus accompanying the selected investments to better understand these costs. In the case of assets held in a brokerage or managed account, they should also review the custodian's pricing schedule. These disclosure documents are available from your Adviser. Investment products vary widely in their costs, objectives and features. Because of this wide selection, your Crown Adviser will be faced with conflicts of interest if one investment product generates more compensation than a competing product. Nonetheless, Advisory Associates have a fiduciary duty to select the best option for the client, to eliminate or mitigate conflicts of interest when possible, and to disclose the conflict if mitigation options are not available. Associates are trained to discuss and offer the account types and investment types that appear to be most suitable for a client's individual situation based on the information obtained from the client. Crown Capital Securities, LP - IA firm brochure Page 7 of 34 03/31/2023 Investment Supervisory Services Crown Heritage Program (Wrap Fee or Non-Wrap Managed Account Program Options) The Heritage Program, through the Advisory Associate, will provide clients with various monitoring, supervision, consolidated reporting, and periodic recommendation services. The services are customized for each client to meet their personal investment goals and objectives. Advisory Associate will gather personal financial data from the client based on personal discussions in which goals and objectives are established. The Advisory Associate will assist a client in determining the suitability of the Program and assist Client in setting appropriate investment objectives and selection of a Wrap or non-Wrap account. Advisory Associate will maintain regular communications with Client in order to determine any change in Client's goals and objectives. Each Advisory Associate chooses his or her research methods and investment strategies, and will operate according to his or her individual investment management philosophy. Selection and use of available research reports and analytical tools, or other resources will be determined by the

Advisory Associate. Based upon the investment objectives and risk tolerances of the client, Advisory Associate will assist the client in the selection of a portfolio, initiate the steps necessary, including receipt of investment funds, to open client's Heritage account and to initiate purchases and sales of various asset classes which will be funded by investments chosen by the client from a list of investments approved for use by Crown. The client will authorize Crown to purchase and sell on a non-discretionary or discretionary basis: mutual funds, equities, fixed income and other investments approved by client and Crown pursuant to investment objectives chosen by the client. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. We will manage individual portfolios on a non-discretionary or discretionary basis, as directed by the client. Crown Heritage Adviser Advantage Wrap Programs (Wrap Fee Program) The Crown Heritage Adviser Advantage Wrap Program consists of three distinct programs; (1.) The Crown Heritage Adviser Advantage Model Management Program, (2.) The Crown Heritage Adviser Advantage Wrap Strategists Program and (3.) the Crown Heritage Adviser Advantage Separate Accounts Program (hereafter collectively referred to as “the Heritage Adviser Advantage Wrap Program”). The Crown Heritage Adviser Advantage Model Management Program: The Heritage Adviser Model Management Program is a versatile asset management service offered by Crown in which clients pay an asset-based advisory fee for individualized portfolio management services and the execution of transactions. The Adviser Advantage Model Management Program is a wrap fee program sponsored and managed by Crown. Crown and its Advisory Associates may participate as a manager(s) or sub- advisers in the Adviser Advantage Model Management Program. Through the Adviser Advantage Model Management Program, Crown provides continuous advice regarding the investment of client funds based on the individual needs of the client. The Adviser Advantage Model Management Program accounts are managed in the same manner as the other investment supervisory services offered by Crown. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client's individual objectives, time horizons, risk tolerance, and liquidity Crown Capital Securities, LP - IA firm brochure Page 8 of 34 03/31/2023 needs. We may also review and discuss a client's prior investment history, as well as family composition and background. We will manage Adviser Advantage Model Management Program accounts on a non-discretionary basis, generally. Thus, we will contact and obtain the client's approval prior to the investment of the assets in a client's account. Under certain circumstances Crown and its Advisory Associates may manage Adviser Advantage Model Management Program accounts on a discretionary basis. Portfolio supervision is guided by the stated objectives of the client (e.g., growth, income, growth and income, etc.), with account management influenced by account type (e.g., IRA, Roth, Community Property, etc.). Crown will create a portfolio consisting of one or more of the following: load or load-waived mutual funds, variable products, stocks, bonds, commercial paper, money market shares, CDs, exchange traded funds (“ETF”) and other investment products. Crown will recommend an allocation of assets among various investments taking into consideration the overall management style selected by the client. Portfolio weighting between securities and market sectors will be determined by each client's individual needs and circumstances. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. The Crown Heritage Adviser Advantage Wrap Strategists Program: With the Adviser Advantage Wrap Strategist program investors can select from a list of Third Party Asset Managers that offer individual investors actively managed portfolios comprised of either mutual funds or exchange-traded funds. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. ■ Access to actively managed investment strategies ■ An objective, unbiased investment process ■ Ongoing portfolio management The Crown Heritage Adviser Advantage Separate Accounts Program: The Adviser Advantage Separate Accounts program provides individual investors with direct access to global investment managers, many of whom were once available exclusively to large institutional investors. With a separately managed account, client will retain direct ownership of the securities in the portfolio. This allows for greater flexibility, more control and possible tax advantages over other investment vehicles.
• Professional asset management with access to the knowledge and expertise of respected institutional asset managers. If accessed directly, many of these firms are only available for accounts of $25 million or more. Clients can instruct the portfolio managers to make minor adjustments to the portfolio to fit a client's needs. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Tax efficiency management of your account (i.e. since each security transaction has a separate cost basis, capital gains and losses can be recognized as necessary to mitigate the impact of taxes). Crown and its Advisory Associates receive a portion of the wrap fee associated with the Crown Heritage Adviser Advantage Wrap Programs. Clients should refer to the Wrap Fee Program Brochure Crown Capital Securities, LP - IA firm brochure Page 9 of 34 03/31/2023 (Form ADV Part 2A, Appendix 1) for these programs for more detailed information about the services offered in the programs. The Crown Sterling Adviser Program (Wrap and Non-Wrap Managed Account Options) The Crown Sterling Adviser Wrap Fee Program (“Sterling Program”) is a versatile portfolio management platform sponsored and offered by Crown. The Sterling Program is designed to offer clients a diversified, long-term approach to their personal investment goals and objectives through asset allocation, portfolio monitoring, consolidated reporting, and, most importantly, individualized portfolio management. It allows clients to invest in no-load or load-waived mutual funds, variable products, stocks, bonds, commercial paper, money market shares, CDs and exchange traded funds, according to the investor's needs, goals, objectives and preferences. Clients considering participation in the Sterling Program will receive an initial consultation with a Crown Advisory Associate to determine the client's financial situation including investment history, goals and objectives, and special interests or concerns. Based on this consultation and client account documents, the client and the Crown Advisory Associate will select a wrap or non-wrap account and design a portfolio using appropriate investments intended to meet the client's long-term goals. Accounts will be rebalanced to ensure they stay within the client's established allocation. The Crown Advisory Associate will review the strategy periodically, and may make changes in the asset allocation among securities as needed. It is imperative, therefore, for the client to contact the Crown Advisory Associate if the client's financial situation or objectives change. Sterling Advisory Accounts will be custodied at Schwab Advisor Services division of Charles Schwab & Co., Inc. (Schwab) Services: Affiliated and unaffiliated service providers may develop asset allocation models. The Crown Advisory Associate may also develop asset allocation models or use others from outside independent sources. Each Advisory Associate develops his or her own methods of analysis, sources of information, and investment strategies. As such, recommendations by Advisory Associate and individual investment portfolios will differ. The Advisory Associate will manage accounts on an ongoing basis and will review accounts at least annually with the client or upon the client's request. The purpose of the review is to determine whether there have been any changes in the client's financial situation and investment goals and to determine whether any changes in the client's investment portfolio are appropriate. The Advisory Associate also reviews the client's asset mix and makes recommendations regarding changes to the portfolio. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Clients will receive monthly brokerage statements, except for months in which no account activity has occurred, and quarterly statements and performance reports. Clients may call at any time during normal business hours to speak directly with their Advisory Associate or the Crown home office about their account, financial situation, or investment needs. Advisory Referral Services Crown acts as a solicitor on behalf of various independent registered investment advisers, also known as Third Party Asset Managers. Based on a client's individual circumstances and needs, we will assist the client in determining which independent adviser's portfolio management services are appropriate for that client. Factors considered in making this determination, including account size, risk tolerance, and a Crown Capital Securities, LP - IA firm brochure Page 10 of 34 03/31/2023 client's investment experience, are discussed during our consultation with the client. The Third Party Asset Manager will have discretion to select and manage the investments in the portfolio pursuant to its stated objectives. Clients will be able to impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Crown will meet with the client on a regular basis, or as determined by the client, to review the account. We will, when needed, suggest changes in the client's portfolio (''rebalancing''), to more effectively address each client's goals. The client may then instruct the independent adviser to make any or all of the changes we recommended. These recommendations are our own, and are neither recommended nor approved by any independent advisers. Any rebalancing of the portfolio is done with the client's approval, unless the client has specified in their advisory services contract to have the portfolio managed on a discretionary basis, and will be reviewed and implemented by the independent investment adviser. At the time of conducting the advisory solicitation, Crown will ensure that all federal and/or state specific requirements governing solicitation activities are met.