A. Description of Your Advisory Firm Poehling Capital Management, Inc. (“PCM” and/or “the firm”), a Wisconsin corporation, is headquartered in Madison, Wisconsin, with a branch office located in La Crosse, Wisconsin. PCM was formed in May of 2004 and is principally owned by Thomas Poehling. PCM is an investment adviser providing financial planning, estate planning, and discretionary and non-discretionary investment management services to its clients. B. Description of Advisory Services Offered PCM is an independent investment advisory and financial planning firm offering a variety of financial services to individuals and high-net-worth individuals, trusts, pension and profit sharing plans, and charitable organizations. Advisory services may include investment strategy, portfolio management, financial planning, and estate planning, as well as selection of separate account managers. For its discretionary asset management services, PCM receives a limited power of attorney to effect securities transactions on behalf of its clients that include securities and strategies as described in Item 8 of this Brochure. In addition, PCM will remind clients of their obligation to inform the firm of any changes to their personal financial circumstances, investment objectives or risk tolerance, and modifications or restrictions that should be imposed on the management of their accounts. PCM will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives, and tolerance for risk. B.1. Financial Planning Services PCM’s professionals interview each client at length to determine the client’s goals, objectives, investment time horizon, and risk tolerance. PCM reviews documents supplied by the client such as wills, insurance policies, and income tax returns. Generally, any of the service categories listed below, on a stand-alone basis, require a minimum of ten (10) hours to compile the necessary data to provide the requested service. In the event the client selects an additional service category, each additional service category would add approximately two (2) to five (5) hours of additional time to complete; for example, the selection of two service categories would require twelve (12) to fifteen (15) hours. Please note these are good faith estimates. Factors that could drive the amount of time and cost higher are the number and complexity of assets, number of securities accounts, number of trusts, number and complexity of corporate entities, client-imposed requirements, complexity of tax situation, and related factors. Based on the client’s needs, financial planning services may include (but are not limited to) the following: ▪ Personal Financial Planning This includes an analysis of family records, budgeting, evaluation of liability issues, estate planning, and determination of financial goals. ▪ Cash Flow and Tax Planning This includes spending analyses and income tax planning. PCM counsels clients concerning the current and future tax effects of various investment vehicles. ▪ Retirement Planning PCM helps clients determine their retirement goals and formulates investment strategies to assist in reaching those goals. ▪ Investment Planning PCM evaluates investment alternatives and their effect on a client’s portfolio. PCM recommends that all clients work closely with their attorney, accountant, insurance agent, and investment advisor to implement a financial plan. B.2. Investment Management Services For discretionary investment management services to clients with assets generally greater than $250,000, PCM offers its value-oriented investment methodology through a series of model portfolios that span each of the risk tolerance categories across the risk spectrum. PCM invests in securities of large capitalization companies that are selling at significant discounts to their intrinsic value, with additional investments in non-correlated securities that serve to reduce overall portfolio risk and volatility. This strategy involves the utilization of quality companies with strong financials run by experienced, shareholder-friendly management teams that are selling at significant discounts to historical valuation metrics and can be acquired at attractive prices. PCM’s primary focus will be on publicly traded equities (common and preferred stocks), exchange-traded funds, open end mutual funds, fixed income (taxable and tax-free), and option contracts. Please refer to Item 8 of this Brochure for a complete listing of the types of securities for which PCM provides advice. Client portfolios are managed on an individual customized basis, taking into account the client’s investment goals, objectives, risk tolerance, and other financial circumstances. PCM reserves the right to offer investment management program strategies in the future whereby, if appropriate, clients will elect to invest in a PCM-offered discretionary investment management program

strategy. In the majority of instances, PCM will evaluate a host of risk management factors (client account size, investment allocation parameters, withdrawal rate, etc.), which may result in the recommendation of one or more third-party separate account managers to manage one or more asset classes that fall outside the scope of PCM’s core investment management competency and/or in order to achieve proper diversification. Please be advised that in such instances, PCM acts in the capacity of an investment consultant and provides advice as to the most appropriate separate account manager in light of the client’s personal and financial circumstances. PCM’s fees for this service are the same as if it were managing the portfolio assets on a proprietary basis. In addition to fees charged by PCM, the client will incur charges from the separate account manager. Although PCM places its clients’ interests first by recommending the most appropriate separate account manager for one or more asset classes outside of its core investment management competency, there is the potential for conflicts in that the client’s fees will always be less if the client utilizes PCM as an investment manager rather than as an investment consultant and allocating all or a portion of the portfolio assets to a third-party separate account manager. As a result, PCM may have an economic incentive to recommend its proprietary managed product over that of the third-party separate account manager. Clients should be aware that they will incur fees from PCM and any third-party money manager utilized. Such additional fees will detract from any increase in portfolio return as a result of hiring the third-party money manager. Please note, though, that PCM would only consider recommending a third-party money manager for those asset classes that fall outside the scope of PCM’s core investment management competency and/or in order to achieve proper diversification based on a host of client-specific risk management factors that are detailed above. In this regard, PCM believes it is placing its clients’ interests first and fulfilling its fiduciary obligation to clients. For clients with assets generally less than $250,000, PCM offers its value-oriented investment methodology through mutual fund models that span each of the risk tolerance categories across the risk spectrum. PCM invests in mutual funds whose portfolio securities consist of small- to large-capitalization companies that the mutual fund manager believes are selling at significant discounts to their intrinsic value, with additional investments in mutual fund securities that consist of lower-correlated securities that serve to reduce overall portfolio risk and volatility. This strategy involves the utilization of mutual funds consisting of quality companies with strong financials run by experienced, shareholder-friendly management teams. B.3. Outside Assets – 401(k) Plans and Related Assets PCM may also provide investment advisory services to retirement plans (“Plan”) or retirement plan participants (“Participants”). PCM may prepare personal asset allocation targets after obtaining and evaluating information concerning individual client circumstances provided by each Participant in response to a risk profiling questionnaire. PCM may provide recommendations as to an appropriate asset class structure and/or securities from a list of securities approved by the plan sponsor (“Sponsor”). The asset allocation and mutual fund recommendations made to such clients may differ from those made by PCM to high-net-worth and affluent individuals and institutions for one or both of the following reasons: ▪ A Participant’s asset allocation target typically consists of a smaller number of asset categories to reflect the relatively smaller size of the Participant’s investment assets. ▪ The Sponsor has constrained the investment alternatives from which PCM may make recommendations. In such cases, PCM may be required to observe quantitative criteria established by the Sponsor in preparing Participant-oriented lists of mutual funds, or to confine the advice given to choices among a relatively narrow set of investment alternatives established by the Sponsor. Participants are informed when the Sponsor of the group imposes constraints on PCM’s ability to recommend mutual funds or other securities. C. Client-Tailored Services and Client-Imposed Restrictions Clients’ accounts will be managed on the basis of their financial situation and investment objectives and in accordance with any reasonable restrictions they have imposed on the management of their accounts—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs PCM does not participate in wrap fee programs. (Wrap fee programs offer services for one all- inclusive fee.) E. Client Assets Under Management As of December 31, 2022, PCM had $335,087,545 of discretionary assets under management, and on $3,006,431 of non-discretionary assets.