General Information Iron Capital Advisors, Inc. (“Iron Capital”) is an investment adviser registered with the U.S. Securities and Exchange Commission, with its principal place of business located in Atlanta, Georgia. Iron Capital began conducting business in 2003. Charles E. Osborne is the sole principal owner of Iron Capital. Please see Brochure Supplements, Exhibit A, for more information on Mr. Osborne and others who formulate advice for clients. As of December 31, 2022, Iron Capital managed $1,105,664,069 on a discretionary basis, and $3,119,360,236 of assets on a non-discretionary basis. SERVICES PROVIDED At the outset of each private client relationship, Iron Capital 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, Iron Capital 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” or “Profile”); and  the client’s investment objectives and guidelines (the “Investment Plan” or “Plan”). 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 Plan outlines the types of investments Iron Capital 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. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by Iron Capital based on updates to the client’s financial or other circumstances. To implement the client’s Investment Plan, Iron Capital will manage the private client’s investment portfolio on a discretionary basis. As a discretionary investment adviser, Iron Capital will have the authority to supervise and direct the portfolio without prior consultation with the client. Notwithstanding the foregoing, clients may impose certain written restrictions on Iron Capital 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 Iron Capital. Iron Capital offers two primary types of services. For individuals, corporations, trusts, estates and charitable organizations, Iron Capital offers Private Client Portfolio Management Services which include individualized investment advice and comprehensive planning. Iron Capital will create an Investment Plan for each individual, utilizing Iron Capital’s Investment Model Allocation Strategies (the “Models”). The Models include a fixed income investment strategy, a global equity investment strategy, an income producing strategy and a concentrated long-term equity opportunity investment strategy. The Models are designed and maintained by Iron Capital’s Investment Committee. The four strategies can be used individually or blended together to meet the client’s unique needs. The Investment Committee may employ a hedging strategy to assist with protecting the portfolio or any position in the portfolio from a loss of value. Hedging may be accomplished by trading in put options, buying certain ETFs or shorting securities. Iron Capital also offers Defined Contribution Plan Services to its pension and profit-sharing plan clients and their Plan participants. As a part of this service, Iron Capital provides independent and customized investment counsel to both the Plan Sponsors and Plan Participants. Iron Capital performs consulting services for Plan Sponsors in any or all of the following areas. 1. Create and monitor an investment policy statement for the plan. 2. Provide Investment Allocation Models for various objectives (such as Growth, Income, Aggressive Growth, etc.) 3. Perform due diligence on existing investment funds and managers. 4. Review and make recommendations based on its manager and fund research and perform searches in order to present mutual funds and managers that conform to the plan’s Investment Policy Statement. 5. Provide quarterly due diligence reports. 6. Assist a sponsor with the process of determining what they would like out of a plan and then assist the sponsor in the search for a plan provider that would meet those criteria. 7. Assist a sponsor with requesting proposals, screening the candidates, and selecting appropriate vendors. 8. Facilitate communication between the sponsor, the provider, vendors, and participants by providing quarterly and annual reports regarding asset allocation, fee disbursement, and performance

of their investments in the plan. 9. Accept inquiries from plan participants regarding investment option explanation. Iron Capital provides Plan Participants with the choice to receive individualized investment advice from Iron Capital and have Iron Capital manage his/her Defined Contribution Plan Account. Iron Capital requires all Participants who choose to use these services to complete an investment questionnaire that provides information regarding the Participant’s investment goals, net worth, risk tolerance, and investment time horizon. Based on that information, Iron Capital will recommend a specific asset allocation in the Participant’s Plan Account. Such asset allocations will be based on the investment models created by Iron Capital. Iron Capital will manage the Participant’s account on an ongoing basis by rebalancing the account as needed to maintain the appropriate allocation. All recommendations are subject to Sponsor or Participant approval. Retirement Plan Advisory Services Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring that prudent procedural steps are followed in making investment decisions. Iron Capital will provide Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The particular services provided will be detailed in the consulting agreement. The appropriate Plan Fiduciary(ies) designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i) make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and (iii) make the ultimate decision as to accepting any of the recommendations that we may provide. Retirement Plan consulting services may be offered individually or as part of a comprehensive suite of services. The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan Fiduciaries may retain investment advisers for various types of services with respect to Plan assets. For certain services, Iron Capital will be considered a fiduciary under ERISA. For example, Iron Capital will act as an ERISA § 3(21) fiduciary when providing non-discretionary investment advice to the Plan Fiduciaries by recommending a suite of investments as choices among which Plan Participants may select. Also, to the extent that the Plan Fiduciaries retain Iron Capital to act as an investment manager within the meaning of ERISA § 3(38), Iron Capital will provide discretionary investment management services to the Plan. With respect to any account for which Iron Capital meets the definition of a fiduciary under Department of Labor rules, Iron Capital acknowledges that both Iron Capital and its Related Persons are acting as fiduciaries. Additional disclosure may be found elsewhere in this Brochure or in the written agreement between Iron Capital and Client Fiduciary Consulting Services  Investment Selection Services Iron Capital will provide Plan Fiduciaries with recommendations of investment options consistent with ERISA section 404(c). Plan Fiduciaries retain responsibility for the final determination of investment options and for compliance with ERISA section 404(c).  Investment Monitoring Iron Capital will continuously monitoring the plan’s investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement. Iron Capital will make recommendations to maintain or remove and replace investment options. Iron Capital prepares due diligence reports on a quarterly basis. The details of this aspect of service will be enumerated in the engagement agreement between the parties. Fiduciary Management Services  Discretionary Management Services When retained as an investment manager within the meaning of ERISA § 3(38), Iron Capital provides continuous and ongoing supervision over the designated retirement plan assets. Iron Capital will actively monitor the designated retirement plan assets and provide ongoing management of the assets. When applicable, Iron Capital will have discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for the designated retirement plan assets in our sole discretion without first consulting with the Plan Fiduciaries. We also have the power and authority to carry out these decisions by giving instructions, on your behalf, to brokers and dealers and the qualified custodian(s) of the Plan for our management of the designated retirement plan assets.  Discretionary Investment Selection Services Iron Capital will monitor the investment options of the Plan and add or remove investment options for the Plan without prior consultation with the Plan Fiduciaries. Iron Capital will have discretionary authority to make and implement all decisions regarding the investment options that are available to Plan Participants.  Investment Management via Model Portfolios. Iron Capital will provide discretionary management of Model Portfolios among which the participants may choose to invest as Plan options. Plan Participants will also have the option of investing only in options that do not include Model Portfolios (i.e., the Plan Participants may elect to invest in one or more of the mutual fund options made available in the Plan, and choose not to invest in the Model Portfolios at all).