Firm Description Arroyo Investment Group, LLC was founded in 1995 (formerly named Odell Investment Group. Arroyo Investment Group, LLC provides personalized confidential financial planning and investment management to individuals, pension and profit- sharing plans, trusts, estates, charitable organizations and small businesses. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, investment management, education funding and retirement planning. Arroyo Investment Group, LLC is strictly a fee-only financial planning and investment management firm. The firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. The principal of Arroyo Investment Group, LLC is also the principal of an affiliated firm, Capital Research Brokerage Services, LLC, a licensed broker/dealer. Clients of Arroyo Investment Group, LLC may also be referred to Capital Research Brokerage Services, LLC for brokerage services outside of their advisory accounts. The services provided by the two companies, therefore, will remain separate and distinct. Investment advice is an integral part of financial planning. In addition, Arroyo Investment Group, LLC advises clients regarding cash flow, college planning, and retirement planning. Investment advice is provided mostly on a discretionary basis. Arroyo Investment Group, LLC does not act as a custodian of client assets. Arroyo Investment Group, LLC places trades for clients under a limited power of attorney and may make account transfers based upon client instructions. Each client initially provides Arroyo Investment Group, LLC with a written statement of their financial situation, desired investment goals and risk tolerance. 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 meeting, which may be by telephone, is free of charge and is considered an exploratory interview to determine the extent to which financial planning and investment management may be beneficial to the client. In providing investment advisory services, the sole standard of care of the Arroyo Investment Group, LLC is to act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent Arroyo Investment Group, LLC in a fiduciary capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims. The Arroyo Investment Group, LLC does not assume responsibility for the accuracy of information furnished by any third party to the client. Principal Owners John P Odell is a 100% stockholder effective April 1, 2017. Types of Advisory Services Arroyo Investment Group, LLC provides investment supervisory services, also known as asset management services. On more than an occasional basis, Arroyo Investment Group, LLC furnishes advice to clients on matters not involving securities, such as financial planning matters, taxation issues, and trust services that often include estate planning. As of 12/31/23, Arroyo Investment Group, LLC manages approximately $243,046,375 in assets for approximately 905 client accounts. Approximately $240,437,697 is managed on a discretionary basis, and $2,608,678 is managed on a non-discretionary basis. Tailored Relationships By their nature, all of our investment advisory services must be based on each client’s individual needs to have any useful validity. As a fiduciary, an investment adviser is to make only those recommendations

that demonstrably are in the client’s own best interests, which means that they, too, must be based on an individual’s stated and/ or established needs, goals, risk tolerance and investment time horizon. The firm seeks to establish this personal dimension through a careful, fact-finding interview and discussions with each client. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without the client’s consent. Types of Agreement The following agreement defines the typical client relationship. Advisory Client Agreement Most clients choose to have Arroyo Investment Group, LLC manage their assets in order to obtain ongoing in-depth investment advice and portfolio review. All aspects of the client’s financial affairs are reviewed, including those of their children. Realistic and measurable goals are set and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The scope of work and fee for an Advisory Client Agreement is provided to the client in writing prior to the start of the relationship. An Advisory Client Agreement includes: cash flow management; investment management (including performance reporting); education planning; retirement planning; as well as the implementation of recommendations within each area. The typical annual Advisory Client Agreement fee is based on a percentage of the investable assets according to the following schedule: Up to $250,000 1.00% $250,001 to $1,000,000 0.80% $1,000,001 to $5,000,000 0.65% Over $5,000,001 0.50% Although the Advisory Client Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement with 10 business days written notice to the other party. At termination, fees will be billed on a pro rata basis for the portion of the quarter completed and will be immediately due and payable. The portfolio value to be used in the calculation will be that of the termination date. Asset Management Assets are invested primarily in no-load mutual funds usually through discount brokers or fund companies. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Discount brokerages may charge a transaction fee for the purchase of some funds. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The brokerage firm may charge a fee for stock and bond trades. Arroyo Investment Group, LLC does not receive any compensation, in any form, from fund companies or discount brokers. Investments may also include: equities (stocks), warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (mutual funds shares) and U. S. government securities. Initial public offerings (IPOs) are not available through Arroyo Investment Group, LLC. Additional information on Asset Management is under Investment Strategy. Termination of Agreement A Client may terminate the aforementioned agreement at any time by providing 10 business days written notice to Arroyo Investment Group, LLC and paying the rate for the time spent on the investment advisory engagement prior to notification of termination. Furthermore, the client has the right to terminate the agreement without penalty within five business days after entering into the agreement. Arroyo Investment Group, LLC may terminate the aforementioned agreement at any time by providing 10 business days written notice to the client.