A. Firm Information Parks Capital is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940 (“Advisers Act”). The Advisor was established in 2005 by its founder Ralph Parks and his key associates Ms. Gina Griffo & Mr. Rajiv Dixit. At the time of its inception, the Advisor was a single member limited liability company (“LLC”) owned by Ralph Parks. On December 31, 2011, the entire ownership interest of the Advisor was acquired by Aspire Capital Management Inc. (“ACM”). ACM is owned by Ms. Gina Griffo (Chief Executive Officer) and Mr. Rajiv Dixit (Chief Investment Officer). B. Advisory Services Offered Parks Capital offers wealth management services to individuals, high net worth individuals, trusts, estates, corporations, and businesses (each referred to as a “Client”). The Advisor is currently managed with a single vision of helping its clients achieve their respective long-term financial goals through active planning, execution and risk management. We take pride in our exceptional customer service. Wealth Management Services The Advisor’s wealth management services consist of a broad range of comprehensive financial planning services and investment management services. Financial Planning Services - Services are offered in several areas of a client’s financial situation, depending on the Client’s goals, objectives, and financial situation. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning may encompass one or more areas of need, including, but not limited to investment planning, tax planning, estate planning, retirement planning, personal savings, education savings, insurance needs. A financial plan developed for the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Parks Capital may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. Recommendations made by the Advisor in connection with the development of a financial plan for a Client pose a conflict between the interests of the Advisor and the interests of the Client. For example, under circumstances where the Advisor’s recommends that a Client purchase an insurance product and the Client accepts that recommendation, the Client can, but is not required to purchase the product from a licensed insurance professional affiliated with the Advisor. Moreover, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to 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 implement the transaction through the Advisor. Investment Management Services With the exception of certain services provided to a subset of retirement plans, the Advisor currently manages all Client assets on a discretionary basis. Parks Capital’s portfolios are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions.

Parks Capital will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Please also review Item 12, Brokerage Practices, for information regarding the factors to consider in selecting and recommending a qualified account custodian that provides custody and safekeeping services for our clients’ accounts. 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 employer- sponsored plan subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) or with respect to a rollover of some or all of the assets of the plan to an Individual Retirement Account (“IRAs”), 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). In these instances, the Advisor will serve as an investment fiduciary as that term is defined under ERISA and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. 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. Retirement Plan Advisory Services Parks Capital provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:  Vendor Analysis  Plan Participant Enrollment  ERISA 404(c) Assistance  Investment Oversight (ERISA 3(21)) Ongoing Investment Recommendation and AThese services are provided by Parks Capital serving in the capacity as a fiduciary under ERISA. provided with ERISA Section 408(b)(2), the Plan Sponsor is provided with written description of Parks Capital’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Each Client is relationship is unique. Once we understand the Client’s goals and risk profile, we construct a customized portfolio that is intended to assist the client in reaching his or her financial goals. The portfolio may consist of individual stocks, bonds, mutual funds, exchange-traded funds (ETFs) and, in some cases, options. All portfolios actively managed to help them navigate through volatility and achieve their goals. With the exception of services provided to a subset of retirement plans, Parks Capital manages all assets on a discretionary basis. Client portfolios are managed on a household basis unless specifically requested by the client. A Client may impose reasonable restrictions on the management of his or her account, provided that the restrictions proposed by the Client are consistent with fall within the agreed upon investment strategy. D. Wrap Fee Programs Parks Capital does not participate in wrap fee programs. Investment management services are provided directly by Parks Capital. E. Assets Under Management As of December 31, 2023, Parks Capital manages $77,086,260 in Client assets, $76,021,509 of which are managed on a discretionary basis and $1,064,751 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.