Hanlon provides investment advisory and investment management services to individuals, investment companies, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations and business entities (“clients”). Hanlon has been an SEC registered investment adviser since February 11, 2002. As of December 31, 2022, Hanlon had $359,206,869 of assets under management of which $338,778,965 are managed on a discretionary basis and $20,427,904 are managed on a non- discretionary basis. The Firm’s Retail Division provides comprehensive investment advisory services which could include financial planning. In general, Hanlon and its advisers provide services to their clients through Hanlon’s Managed Account Platform (“HMAP” or “Platform”, discussed below). When clients open an account with Hanlon, the client will enter into a written Investment Management Agreement with Hanlon which describes the nature and extent of Hanlon’s services, the terms and conditions applicable to such services and the fees to be charged. When specifically requested by a client, Hanlon may provide limited consultation services on investment and non-investment related matters. Any client requesting such services will execute a financial planning agreement with Hanlon at a negotiated fee. The Firm’s Institutional Division operates a Managed Accounts Platform. The Managed Accounts Platform, HMAP, offers Unified Managed Accounts (UMAs) and a robust offering of model portfolios (“Models”) via the Model Marketplace, as well as proposal generation, new account opening, account investment management and account servicing. Additionally, Hanlon creates and manages its own proprietary Models and a proprietary mutual fund. In addition to its own Managed Account Platform, Hanlon implements its investment strategies and services on a variety of platforms including through brokerage accounts, variable insurance, retirement platforms and third-party sponsors. Hanlon’s Managed Account Platform (HMAP) The Firm’s Institutional Division provides a Platform to independent third-party financial representatives, investment advisers, broker-dealers, as well as internal representatives registered with Hanlon (“advisers”). The investment management and investment advisory services provided by Hanlon are primarily offered through its Platform. Through the Platform, Hanlon provides advisers with access to several of its own proprietary Models and those of third-party investment managers (the “Model Managers”) selected by Hanlon as well as access to supporting operational services. The Platform enables advisers to outsource asset management and more efficiently serve their client base and grow their business. At the beginning of the relationship with the client, an adviser will obtain the client’s financial situation, investment objectives, financial goals, tolerance for risk, and investment time horizon (“Investor Risk Profile”). The adviser determines if it is appropriate to recommend that the client opens an account on the Platform. Clients will establish an account with a qualified custodian with whom Hanlon has an existing custodial arrangement. Based on the Investor Risk Profile and investment goals, the adviser will determine the appropriate allocation of the account among the various Models available and Hanlon will manage or effect purchases, sales, or other transactions for the account. In addition, Hanlon will have the authority and discretion to reallocate the assets to another Model, typically in the case where Hanlon, as Platform sponsor, has determined that a Model Manager needs to be replaced after a thorough review. In managing the account assets, Hanlon is specifically permitted to retain all or part of the original, existing investments in the account on day one, or to liquidate such investments, at Hanlon’s discretion, unless noted otherwise by the client and/or their adviser. Neither Hanlon nor any of the Model Managers guarantees the future performance of any Platform accounts, any specific level of performance, the success of any investment decision or strategy that a Model Manager may recommend, or the success of Hanlon’s or the Model Manager’s recommendations in the Platform accounts. The investment and other decisions made by Hanlon for the Platform accounts are subject to various market, currency, economic, political, and business risks, and those investment decisions will not always be profitable. At least annually the adviser will contact the client to determine whether there have been any changes in the client’s financial situation or investment objectives and whether any changes to the client’s account would be appropriate. At least quarterly, Hanlon or a third party selected by Hanlon will provide a report to the client and the adviser reflecting all activity in the account during the preceding period, including performance calculations for the prior periods, all transactions made on behalf of the account, all contributions and withdrawals, all fees and expenses, and the value of the account at the beginning and end of the period. However, the client should note that the statement provided by the custodian holding their account is the official record for all account activity. The client should compare the custodial statement to the report provided by Hanlon for any discrepancies or omissions. If such a discrepancy or omission is found, the client should call their adviser immediately. Model Portfolio Management Services and Model Manager Selection In addition to its own proprietary Models, Hanlon provides continuous model portfolio management services to clients using a selection of third-party Models provided by Model Managers. Each Model is designed to meet a particular investment goal. Under a written agreement between the Model Manager and Hanlon, the Model Manager constructs a Model based on an asset allocation and selects the underlying investments for each portfolio that is based upon a particular investment strategy and/or philosophy. The Model Manager will provide the buy and sell recommendations on an ongoing basis to Hanlon for Hanlon to implement within the Model and therefore those accounts that contain the Model. Hanlon provides an overlay management service for the Models selected for a client’s account by performing all required trades. Depending on the size of the client’s account and the number of and price of securities in a Model, Hanlon, in its sole discretion, Hanlon may allocate the client’s assets to a smaller number of underlying securities in order to effectively manage the Model strategy and may decide to reallocate the client’s assets to the complete Model holdings when Hanlon deems the timing to be appropriate. This variation from the Model portfolio may contribute to performance deviation, including under performance. Hanlon serves as a Manager of Managers due to its ongoing due diligence, review, and selection of the Model Managers available on its Platform. Hanlon’s Research team reviews the universe of all available asset managers and adds a curated list of best-in-class Models to be available on the Platform. Hanlon may at any time hire or terminate a Model Manager at its complete discretion. In the event a Model Manager is removed or departs from Hanlon’s Platform, an appropriate replacement will be selected at Hanlon’s discretion. In addition to managing Models, Hanlon’s Research team provides scorecards on non-model assets based on proprietary and industry-sourced research. Certain Model Managers may pursue an investment strategy that utilizes underlying mutual

funds or ETFs advised by the Model Manager or its affiliates, (“proprietary fund”). In such a situation, the Model Manager may receive fees from this proprietary fund for serving as the investment adviser. These fees are in addition to the management fees the Model Managers receive from the clients for the ongoing management of the Model Portfolios available on Hanlon’s Platform. As discussed below, Hanlon acts as the adviser on a mutual fund, the Tactical Dividend and Momentum Fund. A conflict exists when clients and/or their adviser selects a Hanlon Model because many of the Hanlon Models contain the Hanlon managed Mutual Fund as part of the Model’s underlying holdings. Depending on the Model, the allocation to the Hanlon managed Mutual Fund ranges from approximately 0% to 75% of the total Model holdings. When Hanlon Models are selected, Hanlon will earn a dual fee – an investment advisory fee from the client in addition to investment advisory fees paid to Hanlon from the mutual fund. Investment Advisory Services Brokerage Platforms: Hanlon provides discretionary investment management services, including Platform accounts, for clients that hold assets at certain qualified custodians. For a list of these custodians please contact Hanlon at (888) 641-7100. In addition to Models, investments recommended and made by Hanlon in brokerage accounts include no-load and load-waived mutual funds, including mutual funds managed by Hanlon, ETFs, individual stocks and bonds. See Item 5 for a summary of service fees and custodian fees associated with brokerage accounts. Variable Insurance Products (Variable Annuities and Variable Life Insurance): Hanlon provides discretionary investment management services to the owners of variable annuities and variable life insurance products issued by many different insurance carriers, which are all registered as securities products with the SEC. Clients will execute a contract with Hanlon to manage the investible value of the clients’ insurance account among the available investment options, referred to as “subaccounts.” The client accounts are held in custody at a qualified custodian chosen by the issuing insurance company and listed in the prospectus. Each individual insurance carrier may require the client to execute additional forms to allow Hanlon to provide investment management services. Hanlon executes trades through a process defined by each individual insurance carrier or custodian. In some instances, the issuer of the insurance contract has imposed limitations on the frequency of transactions in certain insurance separate accounts. Hanlon tracks those restrictions and adjusts account allocations accordingly. See Item 5 for a summary of service fees and custodian fees associated with variable insurance products. Retirement Platforms: Pursuant to a written agreement between Hanlon and a qualified plan and/or plan participant, Hanlon may serve as a fiduciary defined by the Employee Retirement Income Security Act of 1974 (“ERISA”) on a variety of different retirement platforms. Hanlon offers the following fiduciary services which are described in greater detail within the written agreement. These services include but are not limited to managing plan and participant accounts, Qualified Default Investment Alternative management (“QDIA”), and selection and monitoring of Designated Investment Alternatives (“Core Funds Services”). The plan or participant accounts are held at a qualified custodian chosen by the plan. Investments recommended and made by Hanlon in retirement platforms include no-load and load-waived mutual funds, ETFs, collective investment funds (“CIFs”), individual stocks and bonds. For certain plans, Hanlon may recommend that the Hanlon Mutual Funds are part of the plan’s investment options. See Item 5 for a summary of service fees associated with Hanlon’s management on retirement platforms. Sponsored Investment Management Platforms or Investment Programs: Pursuant to a written agreement by Hanlon and a program sponsor, Hanlon provides model investment advisory services to the program sponsor’s clients. The terms and conditions of this relationship are determined by the program sponsor. The client signs an agreement with the program sponsor with the help of a program sponsor representative. Through this agreement the program sponsor obtains the information necessary to determine the client’s suitability. The client’s account and funds will be held and cleared through a custodian and broker-dealer selected by the program sponsor. Hanlon will provide discretionary investment advice on the portion of funds delegated to Hanlon. This power and authority are granted by the client in the program sponsor’s agreement. Hanlon will provide model trading instructions to the sponsor or a third party as directed by the sponsor who will be responsible for executing Hanlon’s recommended trades. Hanlon has no responsibility for transaction execution. The program sponsors’ representative is required to provide the client with a copy of Hanlon’s disclosure brochure. For a complete description of the Sponsored Investment Management Platform or Investment Program, refer to the program sponsors Appendix 1 of Form ADV Part 2A. See Item 5 for a summary of service fees associated with Sponsored Investment Management Platforms or Investment Programs. Sub-Advisory and Operational Services Hanlon also provides sub-advisory and operational services to clients indirectly. In this circumstance, a third-party registered investment adviser, broker/dealer or other financial institution executes a Sub- Advisory Agreement or a Platform Service Agreement (collectively “Platform Service Agreement”) with Hanlon. Hanlon provides the independent third party with investment management, investment advisory and/or operational services for their clients. As per the terms of the Platform Service Agreement, the client will enter into a written agreement with the third party but not necessarily directly with Hanlon. When servicing a client’s account in coordination with a third party, the Platform Service Agreement will specify those services to be provided by Hanlon internally versus those services to be provided by the third party as well as any fees to be charged for the specified services. Affiliated Mutual Fund Tactical Dividend and Momentum Fund Hanlon provides investment management services through its affiliated mutual fund, the Tactical Dividend and Momentum Fund (HTDAX, HTDCX, HTDIX, HTDRX) (the “TDM Fund”), an investment company registered under the Investment Company Act of 1940. The TDM Fund invests in ETFs and stocks that represent the 11 sectors of the S&P 500, partially following a rules-based sector allocation. The prospectus, which is sent to clients, contains a complete description of the TDM Fund, its strategy, objectives and costs. Please Note – Combined Fee: Although all mutual funds charge fees (i.e. administrative and investment management fees), because of the TDM Funds’ relationship to Hanlon, a conflict of interest is presented because Hanlon may earn a dual fee. A dual fee may occur when clients open accounts on the Hanlon Managed Account Platform, because Hanlon will earn fees from both (1) its services and investment advice as a separate account manager; and (2) fees from the TDM Fund. Hanlon’s Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the above conflict of interest.