A. Description of Firm Yosemite Capital Management, LLC, a Delaware Limited Liability Company (“YCM” or the “Firm”) is a registered investment adviser headquartered in Newport Beach, California with a satellite office in Wolfeboro, New Hampshire. YCM provides customized portfolio management and financial planning services to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations and other business entities as described further below. YCM is registered with the Securities & Exchange Commission (“SEC”) as an investment adviser and has been in business since 2000. YCM’s principal owner is Paul H. Heckler (“Mr. Heckler”). B. Types of Advisory Services Offered YCM provides advisory services in the form of portfolio management, recommendation of independent advisers, and financial planning, each of which is described more fully below. - Portfolio Management Services YCM offers clients a tailored portfolio management solution based on a thorough understanding of each client’s independent investment objectives. YCM’s portfolio management services encompass not only the traditional asset classes of fixed income, domestic equities and foreign securities, but can also include other asset classes. Such advice will typically involve providing a variety of services and may include investment buy/sell recommendations, asset allocation, recommendation of independent advisers, and the selection of exchange-traded funds (“ETFs”), mutual funds and/or individual securities for the client’s portfolio. The investment advice we provide is customizable, with each account managed according to the investment objectives, needs, guidelines, risk tolerance, and other information provided by the client. This begins through gathering information from each client on an Account Information form, Investment Policy Questionnaire or other similar documentation process. Based upon information received from the client, YCM selects the appropriate model (i.e., either conservative, moderate conservative, moderate, moderately aggressive and aggressive) for on-going management. Depending upon the strategy selected by the adviser, YCM invests primarily invests client assets in ETFs and mutual funds. Depending on the individual needs of the client, additional security types, including but not limited to stocks, bonds, treasuries, variable annuities, foreign securities, real estate investment trusts (“REITs”) and/or private funds (as further described below) are also be utilized at YCM’s discretion. Please refer to Item 8 for additional information about YCM’s investment strategies and their associated risks. YCM generally manages client assets on a fully discretionary basis, but for select clients, may provide non- discretionary management upon request but only on assets held at “Charles Schwab” custodian and at the sole discretion of the Firm. YCM’s discretionary authority may be subject to conditions or restrictions imposed by a client. This may occur when a client restricts or prohibits transactions in a particular security or industry sector, or requests that the Firm place trades with a specific broker-dealer (aka "directed brokerage"). Please refer to Item 12 for additional information. - Recommendation of Independent Advisers Under certain circumstances, YCM may recommend that the client utilize the services of independent, third party investment advisers (“TPAs”) to manage a portion of their portfolio. YCM makes recommendations regarding the suitability of a TPA and their investment style based on, but not limited to, the client’s financial needs, long-term goals, and investment objectives. YCM has a disciplined process for selecting asset managers. The universe of TPAs is screened and reviewed utilizing a multitude of screening metrics. Through fundamental analysis, YCM next reviews the performance and risk attribution of each manager. Then through qualitative analysis, YCM conducts due diligence through meetings, discussions, and evaluation of the characteristics of the various TPAs. Please refer to Item 8 below for additional information on YCM’s methods of analysis and investment strategies. The TPAs selected by YCM are diversified among multiple strategies, asset classes, regions, industry sectors and securities. Once a TPA is selected, YCM continues to monitor the chosen managers to ensure that they adhere to the philosophy and investment style for which they were selected and to ensure that the TPA’s performance portfolio strategies and management remain aligned to the client’s overall investment goals and objectives. YCM will retain discretionary authority to hire and fire TPAs and reallocate the client’s assets to other TPAs, where such action is deemed to be in the best interest of the client. YCM’s ongoing review includes, but is not limited to, assessment of the TPA’s disclosure brochure, performance information, materials (including questionnaire responses) supplied by the TPA, evaluation of the manager’s investment strategies, personnel turnover, regulatory events, ownership changes and corporate earnings reports. Fees for using a TPA vary depending upon the TPA selected, the size of the account and the services provided. The fees charged by the TPAs will be in addition to those charged by YCM (as described in Item 5 below) and will be deducted from the client’s account with its custodian. For information regarding the TPA’s minimum account size, requirements, management services and associated advisory and referral fees please refer to the TPA’s client disclosure brochure and other TPA materials. Clients may be required to sign an Investment Advisory Agreement (“Agreement“) directly with the TPA(s) selected in addition to the one signed with YCM. The client, YCM or the TPA, in accordance with the provisions of those Agreements, may terminate the advisory relationship. If the TPA is compensated in advance, the client will typically receive a pro rata refund of any prepaid advisory fees upon termination of an advisory agreement. Should YCM select a TPA to manage a portion of the client’s portfolio, YCM will instruct the TPA to deliver a copy of the TPA’s disclosure brochure to the client at the time of appointing the TPA. YCM will periodically review the Form ADV delivery process of all TPAs. a. Financial Planning Services YCM provides its clients with a broad range of financial planning services (which may include non- investment related matters). YCM’s financial planning services typically involve one of the following: i. Advanced Financial Planning The process typically involves the collection, organization, and assessment of relevant client data including information concerning the client’s lifestyle, risk tolerance, and cash flow requirements, as well as identification of the client’s financial concerns, goals, and objectives. The primary objective of this Advanced Planning Service is to allow YCM assist the client in developing a cohesive strategy for their investment, tax, legal and insurance planning in order to help meet the client’s individual financial goals and objectives. YCM typically utilizes financial planning software to run various lifetime cash flow scenarios for the client in “real time” which can show a myriad of different scenario options for the client. The client is expected to give YCM all pertinent financial planning information within a reasonable timeframe, in order for YCM’s financial planners to complete their analysis. The client and YCM then jointly review the results of each scenario to establish which plan scenario is best suited for the client’s overall goals, objectives and lifetime cash flow requirements. Clients receiving advanced financial planning services generally receive a written summary of the selected plan’s highlights, based on established assumptions set forth by the client, or meets with a YCM financial planner in person to receive an overview of their current financial condition, an assessment of their risks and opportunities, their current goals, and YCM’s initial recommendations that seek to achieve their goals and mitigate risk. If appropriate, after delivery of the financial planning summary, the client may receive a summary action list of items to do should the client elect to implement the plan. Implementation of the plan can be done through YCM or another financial professional at the client’s full discretion. Generally, to complete the Advanced Financial Planning process, YCM recommends engaging the planner for at least a 6-month period. By paying a monthly/quarterly fee (please see Item 5 below for additional information regarding fees for this service), clients get continuous access to a financial planner who will help the client implement the recommendations, monitor the plan, and adapt the plan to changing circumstances in the client’s life as needed. The client is expected to inform YCM when changes or concerns arise and to provide necessary documents and data for YCM to use in its analysis. YCM will review the new information in the context of the existing plan and share any findings, analysis and potential updated recommendations with the client. Depending upon the needs of the client, the financial plan and the client’s financial situation and goals will be discussed throughout the year. Thereafter, YCM recommends that on an annual basis the plan should be fully reviewed to ensure its accuracy and ongoing appropriateness. Any needed updates will be implemented at that time. ii. Traditional Financial Planning Services YCM is pleased to offer three financial planning services designed to meet client needs.
• YCM’s Essential Financial Planning provides clients with both an assessment of the client’s current situation and recommendations based on the client’s Net Worth and Cash Flow objectives.
• YCM’s Retirement Financial Planning provides clients with both an assessment of the client’s current situation and recommendations based on the client’s long-term goals and retirement planning objectives.
• YCM’s Comprehensive Financial Planning provides clients with an in-depth assessment of the client’s current situation and detailed recommendations based on the client’s long-term goals and retirement planning objectives, long-term care needs, college funding, major purchase analysis and estate planning needs. Specific components of each of these services are outlined in the client agreement. YCM’s traditional financial planning services begins with the collection, organization, and assessment of relevant client data including information concerning the client’s lifestyle, risk tolerance, and cash flow, as well as identification of the client’s financial concerns, goals, and objectives. YCM then performs an analysis of the client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. In general, the financial plan will address the client’s financial situation at the point in time in which the plan is generated. Unlike advanced financial planning however, YCM’s traditional financial planning services (i) generally end at the time that the final financial plan document is delivered to the client, absent terms in the Financial Planning Agreement to the contrary (i.e., a “one-time” engagement); (ii) clients do not pay an ongoing fee (please see Item 5 below for additional details); (iii) implementation and updates of the financial plan are left entirely up to the client; and (iv) the financial

plan deliverable does not typically include multiple financial scenarios. iii. Personal CFO Services YCM also provides its clients personalized CFO services and acts as a “financial quarterback” to oversee its clients’ financial management needs. Among other things, YCM is responsible for interfacing with a client’s team of professional advisors and ensuring they all work in close coordination, with the client’s best interests in mind. Services generally include:
• Evaluation of financial accounts and related documentation, including review of and consolidated reporting of balance sheets, investments, and assets and liabilities, resulting in a financial outlook.
• Engage with existing or help to engage third-party professional advisors (Attorneys, CPAs, Investment, Insurance, Financial Planning, Fiduciary, etc.) to help work towards the client’s best interest. Ultimately, this Service allows us to provide wealth enhancement, wealth transfer and wealth protection and charitable giving options to achieve the client’s objectives. iv. Additional Information Regarding Financial Planning Services Clients receiving financial planning services will have the option of utilizing YCM to implement those plan recommendations. Clients may act on YCM’s recommendations by either: (i) utilizing YCM’s advisory services; (ii) placing securities transactions with any broker-dealer firm selected by the client; or (iii) using a third- party adviser to implement portfolio recommendations. Advice may be given on non- securities matters and any implementation of YCM’s recommendations is entirely at the client’s discretion. Clients are free at all times to accept or reject any of YCM’s financial planning recommendations and further retain the authority and discretion over all such implementation decisions. Should a client decide to implement any recommendations contained in their financial plan, the client may, but is under no obligation to, utilize YCM or one of its representatives to implement those recommendations. Financial planning clients who wish to engage YCM for portfolio management services will be required to enter into a separate written agreement with YCM for such services, for which YCM will be paid a separate and additional fee based on assets under management in accordance with the fee schedule set forth under Item 5, below. There can be no assurance that YCM’s financial planning services or any products recommended by a financial plan are at the lowest available cost. Clients are advised that potential conflicts of interest exist if YCM recommends its own portfolio management services or if YCM representatives recommend products or services offered in such representative’s capacity as a registered representative of a broker- dealer. Specifically, clients should be aware of the following conflicts that exist between YCM’s interests and the interest of the client: 1. If the client implements the financial plan through YCM, the Firm will receive additional payment from the client in the form of advisory fees. This creates an incentive for YCM to make certain recommendations in the financial plan or to advise the client to instruct YCM to implement the plan. Other firms may charge lower fees for providing similar services. 2. If the client is recommended an insurance product by a YCM investment adviser representative (IAR) who independently also is a licensed insurance agent outside of YCM, that individual will receive compensation in the form of commissions generated by such transactions. This creates an incentive to that individual to recommend insurance products or to advise the client to use them to effect the recommended insurance transaction. Such insurance products are available through other agents, who may offer similar products at a lower commission rate. Please note that YCM does not share or receive any insurance commissions. C. Private Investments YCM does from time to time, depending on the sophistication, risk tolerances, and qualifications of the client, recommend that a portion of such client’s assets be invested in certain affiliated and unaffiliated private investments. These include primarily real estate funds, private REITs or private equity funds from publicly traded companies (collectively “Private Funds”). YCM shall continue to render advisory services to the client relative to the ongoing monitoring and review of asset performance and due diligence of the Private Funds. When determining which clients should receive a recommendation to invest in a Private Fund, YCM considers a number of factors, including but not limited to a client’s sophistication and qualification, risk tolerance, investment objectives, and the amount of available assets in the client's account(s). YCM’s goal is to allocate in a fair and balanced manner; however, given these differing factors, the allocation of investment opportunities in Private Funds to our clients is subjective and not all qualifying clients will be provided an investment opportunity. (Please see additional information below and refer to Item 12 for further information on the allocation of Private Fund investments and Item 8 for Risks associated with Private Funds). The client assets with each Private Fund are held at the custodian selected by each Private Fund’s sponsor or investment manager. The performance of these Private Funds typically is reported directly from the sponsor. Clients investing in Private Funds are provided with private placement memorandums and other offering and subscription documentation that detail the nature, risks, and associated fees of each Private Fund. It is important that the client read these documents before investing to fully understand the types of investments, risks and conflicts pertaining to the Private Funds. YCM and certain YCM investment adviser representatives (“IARs”) have affiliations with the issuer, general partner, managing member, or investment manager (as applicable) of certain Private Funds. As further discussed below, this is separate and distinct from YCM, which provides no services for any of the Private Funds, does not collect a fee from the issuer/manager from any of the Private Funds, nor does YCM assess an advisory fee to those clients invested in any affiliated Private Fund. Also, there are times when certain YCM Associated Persons invest in the Private Funds. Mr. Paul Heckler, Managing Director of YCM, is a controlling owner of APHD I, LLC. APHD I, LLC is a minority member of INTRUST Investment Management, LLC, a California limited liability company. INTRUST Investment Management, LLC serves as the Manager to IIM Harrison Partners, LLC (the “IIM Fund”), as well as to IPG Monica Partners, LLC (the “IPG Fund”), which are direct private real estate funds. In this capacity, and only for the IIM Fund and IPG Fund, Mr. Heckler, through his company APHD I, LLC, acts on behalf of INTRUST Investment Management, LLC and receives compensation for his efforts. Important disclosures and material information are provided in each fund’s respective offering documents, which all investors are encouraged to carefully review prior to investing. Both the IIM Fund and IPG Fund are closed to new capital and investors. When suitable and appropriate, the IIM Fund and the IPG Fund were offered to YCM investors who were deemed suitable to invest. In addition, please refer to Items 5, 6, 8, 10, 11, 12, and 14 for further disclosures regarding the IIM and IPG Funds, including the fees received by Mr. Heckler and how YCM addresses the conflict surrounding this arrangement. D. Information Relating to All YCM Services 1. Gathering Individual Client Information The investment advice provided by YCM is customizable, with each client’s portfolio managed based upon the individual needs, objectives, and other financial goals of the client. At the onset of the client relationship, YCM memorializes each client’s investment objectives, risk tolerance, investment guidelines and restrictions, time horizons, tax considerations and other important and necessary information. The information provided will be used by YCM to determine the appropriate portfolio asset allocation and investment strategy or to formulate a customized financial plan (as applicable) for each client. YCM will not assume any responsibility for the accuracy of the information provided by the client. YCM is not obligated to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. Under all circumstances, clients are responsible for promptly notifying YCM in writing of any material changes to the client’s financial situation, investment objectives, time horizon, or risk tolerance. In the event that a client notifies YCM of changes in the client’s financial circumstances, YCM will review such changes and recommend any necessary revisions to the client’s portfolio. YCM will provide investment advisory services and portfolio management services but will not provide custodial or other administrative services. At no time will YCM accept or maintain custody of a client’s funds or securities. Client is responsible for all custodial and securities execution fees charged by the custodian and executing broker-dealer, unless otherwise negotiated. 2. Advisory Agreements Prior to engaging YCM to provide investment advisory services, the client will be required to enter into one or more written agreements with YCM setting forth the terms and conditions under which YCM shall render its services (collectively the “Agreement”). In accordance with Rule 204-3 under the Investment Advisers Act of 1940, as amended (“Advisers Act”), YCM will provide a brochure and one or more brochure supplements to each client or prospective prior to or contemporaneously with the execution of an investment advisory agreement. The Agreement between YCM and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement. YCM’s annual fee shall be prorated through the date of termination and any remaining balance shall be charged or refunded to the client, as appropriate, in a timely manner. Neither YCM nor the client may assign the Agreement without the consent of the other party. Transactions that do not result in a change of actual control or management of YCM shall not be considered an assignment. 3. Restrictions/Guidelines Imposed by Clients Clients may impose reasonable guidelines and/or restrictions on investing in certain securities or types of securities. For example, a client may specify that the investment in any particular stock or industry should not exceed specified percentages of the value of the portfolio. All such guidelines and restrictions must be communicated to YCM in writing. There may be times when certain restrictions are placed by a client, which prevents YCM from accepting or continuing to manage the account. YCM reserves the right to not accept and/or terminate management of a client’s account if it feels that the client imposed restrictions would limit or prevent it from meeting and/or maintaining its investment strategies. E. Assets Under Management As of December 31, 2023, the following represents the amount of client assets under management by YCM on a discretionary and non-discretionary basis: Type of Account Assets Under Management ("AUM") Discretionary $301,466,535 Non-Discretionary $8,454,434 Total: $309,920,969