GeneralInformation D. Scott Neal, Inc. (DSN, we, our, us) was formed in August 1995 and provides financial planning, investment management, and general consulting services to its clients. Our approach to investments seeks to stress the need for flexibility and adaptability to changing economic and market circumstances. At the outset of each client relationship, we spend time with the client asking questions, discussing their investment experience and financial circumstances, and identifying their goals. Clients may hire us to prepare a financial plan that covers one or more areas of their life. From this analysis, recommendations aimed at accomplishing the client’s goals are developed and a written report is prepared and presented to the client for consideration. For clients who retain us for portfolio management services, including those that do not request financial planning, based on all the information we initially gather, we generally develop with each client: ● a financial outline for them based on their financial circumstances, goals, risk tolerance and risk capacity level (the “Risk Profile”); and ● their investment objectives and asset allocation guidelines (the “Investment Strategy”). The Risk Profile reflects the client’s current financial picture and may be forward looking. The Investment Strategy outlines the general types of investments we may make on behalf of the client in order to meet those goals. The Risk Profile and the Investment Strategy are discussed regularly with each client but are not necessarily memorialized in written documents. Finally, where DSN provides only limited financial planning or general consulting services, we generally work with the client to prepare a summary of the specific project(s) to the extent necessary or advisable under the circumstances. FinancialPlanning One of the services offered by DSN is Financial Planning as described below. This service may be provided as a stand-alone service or may be coupled with ongoing investment management. Financial Planning may include advice that addresses one or more areas of a client’s financial situation, which may include but is not limited to estate planning, risk management, budgeting and cash flow controls, retirement planning, education funding, and investment portfolio design and ongoing management. Depending on a client’s particular situation, financial planning may include some or all of the following steps: ● Gathering factual information concerning the client's personal and financial situation. ● Assisting the client in establishing financial goals and objectives. ● Analyzing the client's present situation and anticipated future activities in light of their financial goals and objectives. ● Identifying problems foreseen in the accomplishment of these financial goals and objectives and  Offering alternative solutions to identified problems. ● Making recommendations to help achieve goals and objectives. ● Designing an investment portfolio to help meet the goals and objectives of the client. ● Analyzing estate plans. ● Assessing risk and reviewing health, life and disability insurance needs. ● Making recommendations designed to improve the client’s chances of achieving his or her objectives; and/or ● Providing suggestions on how to measure progress toward the clients’ goals or make changes to the goals as deemed necessary. Once Financial

Planning advice is presented, the client may choose to have DSN assist with the implementation of the client’s financial plan and/or manage the investment portfolio on an ongoing basis. However, the client is under no obligation to act upon any of the recommendations made by DSN under a Financial Planning engagement and/or engage the services of any recommended professional or DSN. InvestmentManagement At the beginning of a client relationship, we meet with the client, ask questions, gather information, and p e r f o r m research and a n a l y s i s as necessary to develop t h e client’ s Investment Plan. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by us based on updates to the client’s financial circumstances or other circumstances. To implement the client’s Investment Plan, DSN may manage the client’s investment portfolio on a discretionary basis or a non-discretionary basis. As a discretionary investment adviser, DSN has the authority to supervise and direct the custodian without prior consultation with the client. Clients who choose a non-discretionary arrangement must be contacted prior to the execution of any t r a d e in their account(s) under management. This may result in a delay in executing recommended trades, which could adversely affect the performance of their portfolio. This delay also normally means that the affected account(s) may not be able to participate in block trades, a practice where orders for the same security for multiple accounts are grouped together for execution in order to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non- discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to their portfolio. Notwithstanding the foregoing, clients may impose certain written restrictions on our management of their investment portfolios, such as prohibiting us from purchasing, holding, or selling certain investments or types of investments in their investment portfolio. Each client should note that such restrictions may adversely affect the composition and performance of their investment portfolio, but we treat each client individually by considering each purchase or sale for their account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ, and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of DSN. GeneralConsulting In addition to the foregoing services, we may provide consulting services for our clients. These services are generally provided on a project basis, and may include, without limitation: any of the financial planning topics mentioned above, business exit planning, business succession planning, or review of specific investments proposed by the client. The scope and fees for consulting services will be negotiated with each client at the time of engagement for the applicable project. PrincipalOwners The firm’s principal owners are David Scott Neal and Jerome G. Zimmerer. TypeandValueofAssetsCurrentlyManaged As of December 31, 2023, DSN managed approximately $293,019,325 of assets on a discretionary basis and approximately $11,237,937 of assets on a non-discretionary basis.