Affinity Investment Group, LLC (hereinafter 'Affinity', the 'firm' or 'we') is a SEC-registered investment adviser with its principal place of business located in Exeter, New Hampshire. It should be noted that registration as an investment adviser does not require and should not be interpreted to imply any particular level of skill or training. Gregory B. Gagne, who founded the firm in 1998, is the sole owner, managing member and chief compliance officer (CCO). Affinity provides personalized confidential financial planning and investment management services to our clients. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. A written evaluation of each client's initial situation is provided to the client, often in the form of a net worth statement, current asset allocation review, or a combination of both. Separately, the principal and certain other related persons of the firm are, in their individual capacity, licensed as independent insurance agents/brokers. When acting in this capacity, these individuals will earn commissions which are separate and distinct from fees charged for advisory services. In addition, Gregory Gagne, James E. Ellis and Peter Willcox, Jr., a licensed investment adviser representative of Affinity, periodically present financial seminars to the public. These seminars are presented free of charge to attendees and are intended to provide general information regarding investing in the financial markets. The presentations do not purport to address the individual investment needs or objectives of any participant, nor do they include any specific recommendations regarding investments in market sectors or securities. Affinity will manage advisory accounts on a discretionary or non-discretionary basis, as agreed with each client. The selection of a discretionary account allows us to buy and sell investments in a client’s account without asking a client in advance, while the selection of a non-discretionary account will require us to ask for a client’s consent prior to the implementation of any recommended transaction in an account. If a client grants us discretionary authority, we will exercise it until it is terminated in writing. We will exercise the discretionary authority a client grants us any time we decide to change the holdings in a client’s account in accordance with his/her outlined investment objectives. The client always maintains asset control and is required to select the independent broker-dealer to be used for trade execution and custodial services. Clients grant Affinity a limited power of attorney enabling us to place trades on their behalf. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. The initial consultation, which may be conducted by telephone, is free of charge and is considered an exploratory interview to determine the extent to which our financial planning and investment management may be beneficial to the client. Affinity offers the following advisory services to our clients: PORTFOLIO MANAGEMENT Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client on a fee only basis as discussed in Item 5 below. 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 needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Assets are invested primarily utilizing no-load or load- waived mutual funds, although Affinity may also utilize exchange-traded funds, certificates of deposit and/or variable annuities when appropriate to the needs of the client. Before engaging Affinity to provide investment advisory services, clients are generally required to enter into an Investment Advisory Agreement with Affinity setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. To commence the investment advisory process, Affinity will ascertain each client’s investment objective(s) and then allocate the client’s assets consistent with the client’s designated investment objective(s). The mutual funds will be selected on the basis of any or all of the following criteria: the fund's performance history; the industry sector in which the fund invests; the track record of the fund's manager; the fund's investment objectives; the fund's management style and philosophy; and the fund's management fee structure. Once allocated, Affinity provides ongoing supervision of the account(s). Portfolio weighting between funds 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. Exempt Asset Class Holdings: A client may:
• hold securities that were purchased at the request of the client or acquired prior to the client’s engagement of Affinity. Generally, with potential exceptions, Affinity does not/would not recommend nor follow such securities, and absent mitigating tax consequences or client direction to the contrary, would prefer to liquidate such securities. Please Note: If/when liquidated, it should not be assumed that the replacement securities purchased by Affinity will outperform the liquidated positions. To the contrary, different types of investments involve varying degrees of risk, and there can be no assurance that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Affinity) will be profitable or equal any specific performance level(s)In addition, there may be other securities and/or accounts owned by the client for which Affinity does not maintain custodian access and/or trading authority; and,
• hold other securities and/or own accounts for which Affinity does not maintain custodian access and/or trading authority. Corresponding Services/Fees: When agreed to by Affinity, Affinity shall: (1) remain available to discuss these securities/accounts on an ongoing basis at the request of the client; (2) monitor these securities/accounts on a regular basis, including, where applicable, rebalancing with client consent;(3) shall generally consider these securities as part of the client’s overall asset allocation; and, (4) report on such securities/accounts as part of regular reports that may be provided by Affinity; and, (5) include the market value of all such securities for purposes of calculating advisory fee. Reporting Services: Affinity can also provide account reporting services, which can incorporate client investment assets that are not part of the assets that Affinity manages (the “Excluded Assets”). Unless agreed to otherwise, the client and/or his/her/its other advisors that maintain trading authority, and not Affinity, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless also agreed to otherwise, Affinity does not provide investment management, monitoring or implementation services for the Excluded Assets. If Affinity is asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and Affinity shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. The client can engage Affinity to provide investment management services for the Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between Affinity and the client. Client Directed Orders: From time to time, certain clients may direct Affinity to purchase or sell securities on their behalf (“client directed transactions”). Affinity does not take investment advisory responsibility for such transactions. Further, we retain the discretion to include or exclude such investments from the client's portfolio managed by Affinity and our calculation of advisory fees. The amount of the fee and the billing terms will be agreed upon in advance with the client. ESG Investments: Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that maintain an acceptable ESG mandate can be limited when compared to those that do not, and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Affinity), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. Affinity does not maintain or advocate an ESG investment strategy, but will seek to employ ESG if directed by a client to do so. Affinity’s ESG security selection is typically limited to select Exchange Traded Funds (“ETFs”) that are managed by unaffiliated third parties. As such, Affinity has no control over the selection of investments within those ETFs and does not administer any positive or negative screens to assess the appropriateness of any individual securities bought or sold for the ETFs. Instead, Affinity relies on the representations and screening processes of the third- party advisers responsible for managing each ETF. While Affinity will conduct due diligence on each ETF’s overall investment mandate and philosophy, Affinity cannot guarantee that each security held within the ETF structure will align with the ESG objectives and restrictions expressed by its clients. WE DON’T RECOMMEND Cryptocurrency: For clients who want exposure to cryptocurrencies, including Bitcoin, Affinity, will advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services, but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, Affinity will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. Please Note: Affinity does not recommend or advocate the purchase of, or investment in, cryptocurrencies. Affinity considers such an investment to be speculative. Please Also Note: Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal. FINANCIAL PLANNING / CONSULTING Affinity may also provide financial planning and related consulting services regarding matters such as tax and estate planning, insurance, annuities, etc. on a stand-alone basis per the terms and conditions of a separate written agreement and fee, the fee for which shall generally be based upon the individual providing the service and the scope of the services to be provided. Prior to engaging Affinity to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with Affinity setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Affinity commencing

services. Financial planning and consulting recommendations are not limited to any specific product or service offered by a broker dealer or insurance company. All recommendations are of a generic nature. 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. Should the client choose to implement some or all of Affinity's recommendations, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. To the extent requested by a client, we may recommend the services of other professionals for investment and non-investment implementation purpose (i.e., attorneys, accountants, insurance, etc.), including Affinity’s representatives in their separate individual capacities as licensed insurance agents. The client is under no obligation to engage the services of any such recommended professional. Please Note-Conflict of Interest: The recommendation that a client purchase an insurance commission product from an Affinity representative in his/her individual capacity as an insurance agent, presents a conflict of interest, as the receipt of commissions can provide an incentive to recommend investment and/or insurance products based on commissions to be received, rather than on a particular client’s need. The fees charged and compensation derived from the sale of such insurance and/or securities products is separate from, and in addition to, Affinity’s investment advisory fee. No client is under any obligation to purchase any insurance commission products from any of Affinity’s representatives. Clients are reminded that they can purchase insurance products recommended by Affinity’s representatives through other, non-affiliated insurance agents. If the client engages any unaffiliated professional, and a dispute arises thereafter relative to such engagement, the engaged professional shall remain exclusively responsible for resolving any such dispute with the client. Implementation of financial plan and/or consulting recommendations is entirely at the client's discretion. Typically, the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. MISCELLANEOUS Non-Discretionary Service Limitations. Clients that determine to engage Affinity on a non- discretionary investment advisory basis must be willing to accept that Affinity cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that Affinity would like to make a transaction for a client’s account, and client is unavailable, Affinity will be unable to effect the account transaction (as it would for its discretionary clients) without first obtaining the client’s consent. Retirement Rollovers – Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Affinity recommends that a client roll over their retirement plan assets into an account to be managed by Affinity, such a recommendation creates a conflict of interest if Affinity will earn new (or increase its current) compensation as a result of the rollover. If Affinity provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Affinity is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by Affinity, whether it is from an employer’s plan or an existing IRA. Affinity’s Chief Compliance Officer, Gregory Gagne, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Please Note-Use of Mutual and Exchange Traded Funds: Affinity utilizes mutual funds and exchange traded funds for its client portfolios. In addition to Affinity’s investment advisory fee described below, and transaction and/or custodial fees discussed above, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Affinity generally recommends that Schwab serve as the primary broker-dealer/custodian for client investment management assets. Broker-dealers such as Schwab charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian. While certain custodians, including Schwab, generally (with the potential exception for large orders) do not currently charge fees on individual equity transactions (including ETFs), others do. Please Note: there can be no assurance that Schwab will not change their transaction fee pricing in the future. Please Also Note: Schwab may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. ANY QUESTIONS: Affinity’s Chief Compliance Officer, Gregory Gagne, remains available to address any questions that a client or prospective client may have regarding the above. Cash Positions. Affinity continues to treat cash as an asset class. As such, unless determined to the contrary by Affinity, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Affinity’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Affinity may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Affinity’s advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: Affinity’s Chief Compliance Officer, Gregory Gagne, remains available to address any questions that a client or prospective may have regarding the above fee billing practice. Cash Sweep Accounts. Account custodians generally require that cash proceeds from account transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep account. The yield on the sweep account is generally lower than those available in money market accounts. To help mitigate this issue, Affinity shall generally purchase a higher yielding money market fund available on the custodian’s platform with cash proceeds or deposits, unless Affinity reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to, the amount of dispersion between the sweep account and a money market fund, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. ANY QUESTIONS: Affinity’ Chief Compliance Officer, Gregory Gagne, remains available to address any questions that a client or prospective client may have regarding the above. Portfolio Activity. Affinity has a fiduciary duty to provide services consistent with the client’s best interest. Affinity will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Affinity determines that changes to a client’s portfolio are unnecessary. Clients remain subject to the fees described in Item 5 below during periods of portfolio inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by Affinity will be profitable or equal any specific performance level(s). Reporting Services. Affinity can also provide account reporting services, via Yodlee and Tamarac, which can incorporate client investment assets that are not part of the assets that Affinity manages (the “Excluded Assets”). Unless agreed to otherwise, the client and/or his/her/its other advisors that maintain trading authority, and not Affinity, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless also agreed to otherwise, Affinity does not provide investment management, monitoring or implementation services for the Excluded Assets. If Affinity is asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and Affinity shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. The client can engage Affinity to provide investment management services for the Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between Affinity and the client. Cybersecurity Risk. The information technology systems and networks that Affinity and its third- party service providers use to provide services to Affinity’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Affinity’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Affinity are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although Affinity has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that Affinity does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Client Obligations. In performing our services, Affinity shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify Affinity if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Affinity) will be profitable or equal any specific performance level(s). Disclosure Brochure. A copy of Affinity’s written Brochure as set forth on Part 2A of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each client prior to, or contemporaneously with, the execution of an agreement between the client and Affinity. AMOUNT OF MANAGED ASSETS As of December 31, 2023, Affinity was actively managing approximately $444,910,598 in total assets, of which $380,637,847 are managed on a discretionary basis and $64,272,751 are managed on a non- discretionary basis.