Biechele Royce Advisors, Inc.(“BRA”) is a SEC-registered investment adviser with its principal place of business located in Fishers, Indiana. Biechele Royce Advisors, Inc. began conducting business in 1994. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).
• Justin Biechele Whelan III, President Biechele Royce Advisors, Inc. offers the following advisory services to our clients: INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. 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, create and manage a portfolio based on that policy. During our data-gathering process, Biechele Royce Advisors, Inc. determines 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. We manage these advisory accounts on a discretionary basis. 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. Biechele Royce Advisors, Inc. first identifies each client's unique goals as it relates to their overall needs for income, growth, capital preservation, cash reserves, inflation protection, and any other specific needs. This information is used to determine the appropriate asset allocation for the portfolio, implement the agreed upon allocation, and continuously monitor the portfolio. We believe portfolios need to be actively managed over time for life changes as well as valuation changes in asset classes and securities. A client's investment stages may include, but are not limited to: Accumulation This stage attracts clients with longer time horizons for investments and little or no need for current income. At this stage, the primary objective is accumulating capital for a future need. Equity investments are favored for long term growth along with a small fixed income component for diversification. Preservation Prior to retirement, a gradual transition may occur from accumulation to preservation. This is primarily achieved by introducing more income generating components to the portfolios, resulting in a more conservative portfolio leading up to retirement. In addition to the securities used in the accumulation stage, fixed income and hedged investments may be used to further diversify. Retirement Once reaching this stage, a client's objective often shifts to income generation and capital preservation as primary goals. This frequently requires a more conservative portfolio emphasizing income over growth, but keeping a growth component to hedge against inflation. A carefully constructed portfolio of dividend paying stocks, high quality stocks, multi-sector bonds, hedged equities, and cash may be used to target a level of income as well as growth. As always, portfolios are customized to adhere to each client's unique set of circumstances and needs. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issuers
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable annuities
• Mutual fund shares
• United States governmental securities
• Options contracts on securities
• Interests in partnerships investing in real estate
• Interests in partnerships investing in oil and gas
• Interests in partnerships investing in private placements Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. FINANCIAL PLANNING We provide financial planning services. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a report which provides the client with a detailed financial plan designed to assist the client to achieve his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax, 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.
• 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. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, return objectives, and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a report. Should the client choose to implement the recommendations 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. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. 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. Financial planning 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 offer non-discretionary services. This is mostly offered through retirement plans such as 401k, 403b, and Money Purchase Plans. SUB-ADVISOR SERVICES We serve as a sub-advisor to one or more unaffiliated Registered Investment Advisors, generally via sub-advisory agreement or dual-contract arrangements. We offer Individual Portfolio Management. This includes active investment management through individual public securities, Exchange Traded Funds, and mutual funds. This relationship is not for suitability. We have discretionary authority to management these assets in accordance with the directions from the unaffiliated Registered Investment Advisors. The unaffiliated Registered

Investment Advisor will have the fiduciary responsibility and we will be directed by them. The second service offering would be Investment Advisory Services(IAS), which includes the Individual Portfolio Management Services described above and in addition, includes Financial Planning Services. As a more robust offering this would render higher fees paid to Biechele Royce Advisors, Inc. EAGLE INCOME FUND, LLC Our Adviser also offers The Eagle Income Fund LLC. The Eagle Income Fund, LLC is not required to register under the Securities Act of 1933 or the Investment Company Act of 1940 in reliance upon certain exemptions available to issuers whose securities are not publicly offered. BRA does not have discretion to purchase private equity investments in the Eagle Income Fund, LLC. Clients must sign separate forms and subscription agreements to authorize these purchases. Although BRA manages the separate investment of the Fund on a discretionary basis in accordance with the terms and conditions of the Fund’s offering and organizational documents, investors should be aware that we act as the managing member. We are considered to have custody of these funds. We offer this fund to clients of BRA that are accredited investors. The Funds sole focus invests in a subordinated debenture in the Eagle Financial Services, Inc. The debenture is held on the books of Eagle Financial Services, Inc. The Fund receives the interest from the debenture and distributes it to the members in pro-rata portion. The objective of the Fund will be to return principal after a specified period of time. Current Fund investors and prospective investors in any new Fund launched by Eagle Funds should be aware of the substantial risks associated with investments as well as the terms applicable to such investments. This and other detailed information will be provided in the Fund offering and organizational documents. IRONWOOD INCOME FUND, LLC Our Adviser also offers Ironwood Income Fund, LLC. The Fund is not required to register under the Securities Act of 1933 or the Investment Company Act of 1940 in reliance upon certain exemptions available to issuers whose securities are not publicly offered. BRA does not have discretion to purchase private equity investments in the Ironwood Income Fund, LLC. Clients must sign separate forms and subscription agreements to authorize these purchases. Although BRA manages the separate investment of the Fund on a discretionary basis in accordance with the terms and conditions of the Fund’s offering and organizational documents, investors should be aware that we act as the managing member. We are considered to have custody of these funds. We offer this fund to clients of BRA. The Funds sole focus invests an equity position in the Ironwood Fund VIII, LLC. The Fund is expected to receive semi-annual distributions and pass through to the members in pro-rata portion. The objective of the Fund is appreciation and income. Investors are required to remain in the Fund until it matures which is expected in five years. Current Fund investors and prospective investors in any new Fund launched by Ironwood Income Fund should be aware of the substantial risks associated with investments as well as the terms applicable to such investments. This and other detailed information will be provided in the Fund offering and organizational OVATION INCOME FUND, LLC Our Adviser also offers The Ovation Income Fund LLC. The Ovation Income Fund, LLC is not required to register under the Securities Act of 1933 or the Investment Company Act of 1940 in reliance upon certain exemptions available to issuers whose securities are not publicly offered. BRA does not have discretion to purchase private equity investments in the Ovation Income Fund, LLC. Clients must sign separate forms and subscription agreements to authorize these purchases. Although BRA manages the separate investment of the Fund on a discretionary basis in accordance with the terms and conditions of the Fund’s offering and organizational documents, investors should be aware that we act as the managing member. We are considered to have custody of these funds. We offer this fund to clients of BRA. The Funds sole focus invests an equity position in the Ovation Alternative Income Fund, LP. The Fund is expected to receive quarterly distributions and pass through to the members in pro-rata portion. The objective of the Fund is income. Investors are required to remain in the Fund for one year. Current Fund investors and prospective investors in any new Fund launched by Ovation Funds should be aware of the substantial risks associated with investments as well as the terms applicable to such investments. This and other detailed information will be provided in the Fund offering and organizational documents. BAY POINT INCOME FUND, LLC Our Adviser also offers The Bay Point Income Fund LLC. The Bay Point Income Fund, LLC is not required to register under the Securities Act of 1933 or the Investment Company Act of 1940 in reliance upon certain exemptions available to issuers whose securities are not publicly offered. BRA does not have discretion to purchase private equity investments in the Bay Point Income Fund, LLC. Clients must sign separate forms and subscription agreements to authorize these purchases. Although BRA manages the separate investment of the Fund on a discretionary basis in accordance with the terms and conditions of the Fund’s offering and organizational documents,investors should be aware that we act as the managing member. We are considered to have custody of these funds. We offer this fund to clients of BRA. The Funds sole focus invests an equity position in the Bay Point Capital Partners, LP. The Fund is expected to receive quarterly valuations and pass through to the members in pro-rata portion. The objective of the Fund is income with little correlation to traditional equity and fixed income securities. Investors are required to remain in the Fund for one year. Current Fund investors and prospective investors in any new Fund launched by Bay Point Income Fund, LLC should be aware of the substantial risks associated with investments as well as the terms applicable to such investments. This and other detailed information will be provided in the Fund offering and organizational documents. EAGLE INCOME FUND III, LLC Our Adviser also offers The Eagle Income Fund III, LLC. The Eagle Income Fund III, LLC is not required to register under the Securities Act of 1933 or the Investment Company Act of 1940 in reliance upon certain exemptions available to issuers whose securities are not publicly offered. BRA does not have discretion to purchase private equity investments in the Eagle Income Fund III, LLC. Clients must sign separate forms and subscription agreements to authorize these purchases. Although BRA manages the separate investment of the Fund on a discretionary basis in accordance with the terms and conditions of the Fund’s offering and organizational documents, investors should be aware that we act as the managing member. We are considered to have custody of these funds. We offer this fund to clients of BRA that are accredited investors. The Funds sole focus invests in a subordinated debenture in the Eagle Financial Services, Inc. The debenture is held on the books of Eagle Financial Services, Inc. The Fund receives the interest from the debenture and distributes it to the members in pro-rata portion. The objective of the Fund will be to return principal after a specified period of time. Current Fund investors and prospective investors in any new Fund launched by Eagle Funds should be aware of the substantial risks associated with investments as well as the terms applicable to such investments. This and other detailed information will be provided in the Fund offering and organizational documents. AMOUNT OF MANAGED ASSETS As of 03/24/2024, we were managing $659,842,002 of clients' assets on a discretionary basis. Also, we were managing $58,390,332 on a non-discretionary basis.