A. Firm Information Novare Capital Management, LLC (“NCM” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of North Carolina. NCM was founded in 1999 and became a registered investment advisor in February 2003. NCM is primarily owned by William G. Baynard, Jr. (Managing Director), Don E. Olmstead (Managing Director), and The Baymen Group, LLC (Member). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by NCM. B. Advisory Services Offered NCM provides investment advisory services to individuals, high net worth individuals, trusts, estates, charitable organizations, businesses and financial institutions (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate conflicts of interest. NCM’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services NCM provides Clients with comprehensive wealth management services, which generally include a broad range of comprehensive financial planning services as well as discretionary and/or non-discretionary management of investment portfolios. Financial Planning Services – At the outset of each Client relationship, NCM spends time with the Client, asking questions, discussing the Client’s investment experience and financial circumstances, and reviewing options for the Client. Based on its reviews, NCM generally develops with each Client: ● a financial outline for the Client based on the Client’s financial circumstances and goals, and the Client’s risk tolerance level (the “Financial Profile”); and, ● the Client’s investment objectives and guidelines (the “Investment Policy Statement”). The Financial Profile is a reflection of the Client’s current financial picture and a look to the future goals of the Client. The Investment Policy Statement outlines the types of investments NCM will make on behalf of the Client to meet those goals. The Profile and the Plan are discussed regularly with each Client but are not necessarily written documents. NCM’s financial planning services normally address areas such as general cash flow planning and retirement planning. The goal of this service is to assess the financial circumstances of the Client to more effectively develop the Client’s Investment Policy Statement. Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to affect the transaction through the Advisor. Investment Management Services – To implement the Client’s Investment Policy Statement, NCM will manage the Client’s investment portfolio on a discretionary or non-discretionary basis. NCM generally constructs investment portfolios consisting of individual stocks and bonds, The Advisor may also utilize of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”), alternative investments and options to achieve the Client’s investment goals. The Advisor may also retain certain legacy investments based on portfolio fit and/or tax considerations. Page 5 NCM may retain mutual funds on a fund-by-fund basis. Under limited circumstances due to specific custodial and/or mutual fund company constraints, material tax consideration, and/or systematic investment plans, NCM will select, recommend and/or retain a mutual fund share class that does not have trading costs, but does have higher internal expense ratios than institutional share classes. NCM will seek to select the lowest cost share class available that is in the best interest of each Client and will ensure the selection aligns with the Client’s financial objectives and stated investment guidelines. Under a discretionary arrangement, NCM will have the authority to supervise and direct the portfolio without prior consultation with the Client. Under a non-discretionary arrangement, Clients must be contacted prior to the execution of any trade in the account[s] under management. This can result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account[s] will not be able to participate in block trades, a practice designed 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 the portfolio. Notwithstanding the foregoing, Clients may

impose certain written restrictions on NCM in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each Client should note, however, that restrictions imposed by a Client may adversely affect the composition and performance of the Client’s investment portfolio. Each Client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the Client’s 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 NCM. At no time will NCM accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Participant Account Management (Pontera) As part of the Advisor’s Investment Management Services, when appropriate, the Advisor will use a third-party platform, Pontera Solutions, Inc. (“Pontera”), to facilitate management of held away assets such as defined contribution plan participant accounts, with investment discretion. The platform enables the Advisor to gain access to Client account without having access through the Client’s credentials. This independent advisor access ensures that the Advisor will not have custody of Client funds or securities when implementing trades for the Client. The Advisor is not affiliated with the platform in any way and receives no compensation from the platform. A link will be provided to the Client allowing them to connect their account[s] to the platform for the Advisor’s secure access. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Schwab Pledged Asset Line – The Advisor may introduce certain Clients to a Pledged Asset Line, a non-purpose revolving line of credit made available through Charles Schwab Bank, secured by eligible assets held in an account maintained at the Custodian (“Lending Program”). In such instances, the Client’s assets in their account[s] at the Custodian will be utilized as collateral for a non-purpose revolving line of credit. The recommendation of a Lending Page 6 Program presents a conflict of interest as the Advisor will continue to receive investment advisory fees for managing the collateralized assets in the Client’s account[s]. Clients are not obligated to engage the Advisor for the Lending Program. For additional information related to the risks involved non-purpose loans and lines of credit, please see Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss. C. Client Account Management Prior to engaging NCM to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ● Establishing an Investment Strategy – NCM, in connection with the Client, will develop an Investment Policy Statement that seeks to achieve the Client’s goals and destinations. ● Asset Allocation – NCM will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk of each Client. ● Portfolio Construction – NCM will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. ● Investment Management and Supervision – NCM will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs NCM does not manage or place Client assets into a wrap fee program. Investment advisory services are provided directly by NCM. E. Assets Under Management As of December 31, 2023, NCM manages $1,509,026,137 in Client assets, of which $1,506,029,095 are managed on a discretionary basis and $2,997,042 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.