Naples Asset Management Company®, LLC (“NAMCOA”) is a registered investment adviser (“RIA”) based in Naples, Florida and is registered to conduct business in states it is registered or qualifies for an exemption or exclusion from registration requirements. We are organized as a limited liability company under the laws of the State of Florida. We have been providing investment advisory and consulting services since 2003. Paul McIntyre is the Managing Director, owner and serves as the Chief Compliance Officer of the firm. NAMCOA provides investment advisory services through supervised financial professionals who are investment advisory representatives (“IARs”) of the firm. The majority of IARs conduct their investment advisory activities under NAMCOA. However, an IAR is allowed to conduct his/her investment advisory activities under a separate business name or “DBA” (“doing business as”). Such advisors, while registered with NAMCOA as IARs, are independent contractors. NAMCOA supervises the IARs’ investment advisory activities. Investment advisory agreements (“IAAs”) and marketing materials clearly disclose NAMCOA as the RIA with whom clients are engaging for investment advisory services. Currently, we offer the following investment advisory services: ▪ Portfolio Management Services ▪ Retirement Plan Services ▪ Wrap Fee Programs
• Consulting Services
• Investor Education
• Annuity Management Portfolio Management Services NAMCOA offers portfolio management services on a discretionary and non-discretionary basis. NAMCOA may offer an initial complementary general consultation to discuss services available and determine the suitability of a potential client-adviser relationship. Portfolio management services will only begin after the client and NAMCOA have formalized the relationship with a signed Advisory Services agreement. Once the relationship is formalized, NAMCOA and the client will share in a data gathering process to try to determine the client’s personal needs, goals, intentions, time horizons, risk tolerance and investment objectives. Portfolio management services involve ongoing and continuous portfolio management services that include, but are not limited to, risk management, investment policy, asset allocation, active or passive strategy, and performance monitoring. In the delivery of investment management services, NAMCOA provides investment advisory services. Investment objectives may range from conservative income to aggressive growth, with the input of each client, NAMCOA will attempt to construct a diversified portfolio of investments that are within its realm of expertise. Advisory Business (Form ADV Part 2A, Item 4) Model Portfolios To assist clients more effectively reach their financial objectives, IARs (Investment Advisor Representatives) may create or use various types of model investment portfolios. Portfolios Models may range, designed, or characterized by:
• Client Risk Profile: Income to Aggressive Growth.
• Portfolio Objective: Growth & Income, Income, Tax harvesting, Tax-favored, etc.
• Security Type: Exchange Traded Funds (ETFs), Mutual Funds, individual stocks, etc.
• Sector: REITS, Healthcare, Technology, Infrastructure, Equine, Cannabis, etc.
• Custodial Platforms: NAMCOA has entered into agreements with The Pacific Financial Group, Envestnet Asset Management, Inc., SEI Private Trust Company, AssetMark, ePlan, Jackson National (collectively, “Platform Managers”) relating to the investment advisory and performance measurement services that may be provided through a third-party Platform Manager. Third Party Advisors and Platform Managers are responsible for managing model portfolios, with client risk profile input from the IAR. Model Portfolios are rebalanced on an ongoing basis as market prices change (as opposed to quarterly or annually) to take advantage of, and guard against short term price fluctuations. In all cases, Exchange Traded Funds (ETFs) are used to gain exposure to different asset classes in a cost-effective and broad- based manner. Clients may provide instructions to NAMCOA to refrain from investing in particular industries, invest in limited amounts of securities, and/or request that NAMCOA issue checks or electronic fund transfers to or for the benefit of the client. The checks or fund transfers will be completed by the custodian and sent directly to the client. Please note: NAMCOA does not have custody over client funds. Held Away Assets (Pontera) We use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly, and allocation changes will be made as deemed necessary. Wrap Fee Program and Fees A “wrap fee program” provides clients with at least two types of services, investment advisory and trade execution, for a single “wrap” fee. The wrap fee is paid to Naples Asset Management Company, LLC (" NAMCOA"). The Wrap Fee Program (the “Program”) covers participating clients of all fees and costs associated with portfolio management, trade execution, custody, and client reporting relating to Program assets. All portfolio management services for clients participating in the Program are provided by the Advisor. Advisor's annual wrap fees are based on a percentage of the market value of the client’s Program assets and generally range from a minimum of 1.00% to a maximum of 2.00%. All wrap fee arrangements, however, are negotiated individually with each client based on various objective and subjective factors. These factors include, but are not limited to, the amount of the assets placed under Advisor’s management, the investment strategy that the client’s Program assets are managed under, the level and scope of the overall investment advisory services to be rendered and the complexity of the engagement. The final fee schedule negotiated with each Program client will be delineated in the client’s Investment Advisory Agreement (“IAA”) with Advisor. Program clients should be aware that the wrap fees they pay may be more than the aggregate costs they would incur if they purchased each of the services provided by the Program separately. Additionally, the wrap fee is not based on the number of transactions effected in Program accounts and consequently, the likelihood that a client may pay higher investment advisory fees increases as the number of transactions effected in a client’s Program account(s) decreases. Furthermore, while the Advisor does not charge Program clients higher fees based on the volume of trading in their Program account, the Advisor may have an incentive to limit trading in a client’s Program account(s) because the execution costs that the Advisor incurs can be based on the aggregate number of trades executed in the accounts of Program clients. Program clients should also be aware that the Advisor has a conflict of interest when it recommends mutual funds that are available for purchase on a no-load and/or no-transaction fee basis over other comparable mutual funds that are subject to sales charges because Advisor may not incur any expenses relating to such transactions, which ultimately reduces Advisor’s costs in operating the Program, and because such cost savings are not passed through to Program clients. Program clients generally elect to have wrap fees deducted directly from their custodial account(s), but, in the alternative, may elect to be billed for such fees. The IAA and/or the custodial/clearing agreement will authorize the custodian to debit client accounts for the amount of Advisor's wrap fee and authorize the custodian to remit such fee to Advisor. In the limited event that Advisor bills the client directly for wrap fees, payment is due upon receipt of Advisor’s invoice. Wrap fees are generally deducted or billed monthly in advance, based on the market value of the Program assets under Advisor's management on the last business day of the previous month, but may be billed quarterly in advance or monthly or quarterly in arrears in certain circumstances. Wrap fees are prorated for any new account opened during a calendar month or quarter based on a 360-day year/30-day month calendar. Advisor does not prorate its wrap fees with respect to cash flows except as part of a new account opening. The IAA may be terminated within the first five days without penalty but subject to market fluctuation. Afterwards the IAA will continue in effect until terminated by either party by written notice in accordance with the terms of the IAA. In the event that a Program client terminates their IAA prior to the end of a month or quarter and is billed in advance, the client will receive a refund of any unearned wrap fees that were deducted from their custodial account(s). If the Program client was billed in arrears, the client will be responsible for paying pro-rated wrap fees for services rendered up to and through the date of termination. The amount of the refund is calculated by dividing the number of days left in the quarter after the date of termination by the total number of days in the quarter using a 360-day year/30-day month calendar and multiplying that amount against the wrap fee that was received by Advisor in advance for the month or quarter. The value of any amount owed is calculated by dividing the number of days in the month/quarter up to and including the date of termination by the total number of days in the month/quarter using a 360- day year/30- day month calendar and multiplying that amount against the market value of the Program assets on the date of termination. (See Wrap Fee Brochure for further information). Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title 1 of the Employee Retirement Income Act (ERISA) and the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put out interest ahead of yours. Under this special rule’s provisions, we must: o Meet a professional standard of care when making investment recommendations (give prudent advice); o Never put our financial interests ahead of yours when making recommendations (give loyal advice); o Avoid misleading statements about conflicts of interest, fees, and investments; o Follow policies and procedures designed to ensure that we give advice that is in your best interest; o Charge no more than a level fee that is reasonable for our services; and o Give you basic information about conflicts of interest. Types of Investment Depending on the needs of the clients, NAMCOA may recommend or provide

consulting services on listed securities, exchange traded funds, mutual funds, corporate bonds, U.S. Government securities, tax-exempt municipal bonds, options, DSTs (Delaware Statutory Trusts) real estate and other fixed income securities. NAMCOA does not limit its advice to any specific types of investments. Types of Investments Services NAMCOA provides portfolio management, investment advisory and consulting services to individuals, high net worth individuals, corporate pension and profit-sharing plans, Taft-Hartley plans, charitable institutions, foundations, endowments, broker dealers, municipalities, registered mutual funds, private investment funds, registered investment advisors, trust programs, and fixed and variable annuities. NAMCOA’s advisory relationship is formalized at the time NAMCOA and the client sign an Advisory Services Agreement. Third Party Managed Account Solutions In addition to offering services directly to investment advisory clients, the Advisor also provides investment management services through and sponsored by independent, third-party investment firms, other registered investment advisory firms, and investment management consultants (collectively, “Third Party Advisors” or “Platform Managers”). NAMCOA has entered into agreements with The Pacific Financial Group, Envestnet Asset Management, Inc., SEI Private Trust Company, AssetMark, ePlan, or/and other such firms (collectively, “Platform Managers”) relating to the investment advisory and performance measurement services that may be provided to a Client by Advisor and a Platform Manager. Advisor may determine that Client may be a suitable participant and may recommend to Client that Client participate in the Managed Account Solutions Program (the “Program”) offered by Platform Manager. Third Party Advisors and Platform Managers are responsible for managing brokerage accounts for their customers. Client understands that a Platform Manager and Advisor are not affiliated other than through jointly providing services to the Program. A Platform Manager, a registered investment adviser, operates the technology platform on which the Program functions and renders investment advice to Advisor and/or Client, including recommending an appropriate asset allocation for Client and specific investment managers or investment products. Aspects outlining services, costs and management options are disclosed in the appropriate Third-Party Advisor’s or Platform Manager’s Firm Brochure (Form ADV Part 2), other disclosure brochures/documents, investment advisory contracts, and account opening documents. Each investor will be required to sign an advisory agreement directly with the Third-Party Advisor selected. In addition to a Platform Manager’s advisory services offered in their Program, other advisory service tools may be provided, including administrative and technology services. A Client’s Advisor determines which services and Programs to utilize with its Clients and may utilize the services of other third-party services providers in conjunction with the Programs that a Client may discuss with their Advisor for a description of that Advisor’s specific use of a Program. The services offered by a Platform Manager may include:
• Assessment assistance of the Client’s investment needs and objectives
• Investment policy planning assistance
• Assistance in development of an asset allocation strategy designed to meet the Client's objectives
• Recommendations on suitable style allocations
• Identification of appropriate managers and investment vehicles suitable to the Client’s goals
• Evaluation of asset managers and investment vehicles meeting style and allocation criteria
• Engagement of selected asset managers and investment vehicles on behalf of the Client
• Ongoing monitoring of individual asset manager’s performance and management for “Approved” investment strategies
• Review of Client accounts to ensure adherence to policy guidelines and asset allocation
• Recommendations for account rebalancing, if necessary
• Online reporting of Client account’s performance and progress
• Self-directed brokerage options to actively manage retirement plan assets For all Programs, Client and Advisor compile pertinent financial and demographic information to develop an investment program that will meet the Client’s goals and objectives. Utilizing the Platform Manager’s tools, Advisor will allocate the Client’s assets among the different options in the Program and determine the suitability of the asset allocation and investment options for each Client, based on the Client’s needs and objectives, investment time horizon, risk tolerance and any other pertinent factors. The Platform Manager’s research team uses a number of proprietary analytical tools and commercially available optimization software applications in developing its asset allocation strategies. Among the factors considered in designing these strategies are historical rates of risk and return for various asset classes, correlation across asset classes and risk premiums. For all Programs, the Client directly owns the underlying securities, mutual funds or Exchange Traded Funds (“ETFs”) in each of the Program’s investment strategies. Mutual funds, ETFs, closed-end funds, unit investment trusts, real estate investment trusts, and exchange traded funds are collectively referred to throughout this document generally as a “Fund” or “Funds.” Retirement Plan Services NAMCOA may provide FLAT-FEE (no commission) advisory and fiduciary services for the following types of corporate retirement plans:
• 401(k)s, 403(b)s and Profit-sharing
• Defined benefit (pension)
• SEPs, SAR SEPs, KEOGHs, Self- employed
• SIMPLE IRAs and SIMPLE 401(k)s
• Deferred compensation plans, including 457 plans NAMCOA may recommend retirement plan services offered by The Pacific Financial Group (“TPFG”). TPFG is a third-party money manager that works with NAMCOA to manage client 401(k), 403b, and 457 plan assets while the participant is working. Aspects outlining services, costs and management options are disclosed in this TPFG’s Firm Brochure (Item 5), other disclosure brochures/documents, investment advisory contracts, and account opening documents. Each investor will be required to sign an advisory agreement directly with TPFG. Services NAMCOA May Offer to Corporate Retirement Plan Clients
• Plan analysis, design, and solution modeling
• Conduct and present a comparative analysis of the services and fees of multiple service providers
• Assist with the creation and ongoing implementation of an Investment Policy Statement for the Plan
• Conduct a regular and ongoing analysis and evaluation of the Plan investments per the terms of the plan’s Investment Policy Statement
• Propose the removal and replacement of investment alternatives as needed per the terms of the Plan’s Investment Policy Statement
• Serve as co-fiduciary with regard to ERISA requirements related to investment manager selection and monitoring
• Provide comprehensive education and consulting to participants Investor Education NAMCOA recognizes that education and awareness are powerful tools in decision making, enhancing investment returns, decreasing portfolio risk and in the fight against investment fraud. NAMCOA offers a variety of investor education programs that can be customized for Employees, 401k Plan participants and other organizations. Please contact us for more information on designing a program to fit your needs. Consulting Services In addition to fee-based or flat-fee advisory services, NAMCOA provides consultations offered at an hourly rate or fixed fee project rate. Project fees will generally be based upon NAMCOA’s hourly rate. Consulting services are not ongoing in nature and terminate upon the conclusion of services. For investors, consulting services can be general in nature or focused on particular component, depending upon the client’s needs. Advice is based upon information provided by the client. Topics and assistance may range from overall investment advisory questions, review of an existing portfolio, project, research and analysis, consultation regarding suitability or verification of statements as may otherwise be desired by the client. When consulting services are focused on certain areas of the client’s interests or needs, the client’s overall financial situation or needs may not be addressed due to the limited scope of the client’s request. NAMCOA is also available to provide services to financial professionals and qualified investors, which may include consultation, research and analysis, document drafting, and other areas of assistance that may be desired. Services are provided hourly at $400 or at a quoted project fee, dependent upon the nature and complexity of the project. Clients are never obligated to utilize the services or companies that may be recommended by NAMCOA. NAMCOA may require a retainer in order to schedule projects. Fees or project balances for consultations are due and payable upon delivery. Types of Consulting Services
• Asset Management Consulting Services. NAMCOA may provide consulting services to registered investment advisors; FINRA members, Mutual Fund Sponsors, Fund Issuers and Bank Trust Departments on third party “turnkey” asset management platforms and investment managers.
• Administrative Services. NAMCOA may also provide AML audits to FINRA member broker dealers or for on-going administrative fees for consulting, accounting and administrative services. NAMCOA may provide initial and ongoing consulting to business owners or issuers of private investment offerings.
• Insurance Services. Representatives of NAMCOA, when property licensed in their state, may offer various levels of insurance consulting services and product solutions to clients. This may involve the recommendation of one or more life insurance and annuity products offered through an insurance company that specializes in insurance products. The types of consulting services on insurance product needs may range from immediate annuities, to survivorship life insurance products that may include term life, whole life, universal life, variable universal life, long-term care solutions and structured settlements. Insurance product sales are outside the scope of normal portfolio services offered by the Company.
• Products are selected and recommended by an adviser, on criteria important to the client, including the financial strength of the insurance company, premium cost, declared rates of interest, income and/or annuity purchase rates.
• DST Consulting Services. NAMCOA may offer various levels of consulting and due diligence services and product solutions to clients seeking to engage in a 1031 exchange. This may involve the recommendation or allocation of specific DST investments offered by DST Plan Sponsors. NAMCOA is not affiliated with any DST Sponsor. Products are selected and recommended by an adviser, on criteria important to the client, including the financial strength of the DST Sponsor, objectives set forth by the client.
• Financial Planning Services. Representatives of NAMCOA may offer various levels of financial planning services and product solutions to clients seeking to solve retirement, college, estate, business or other planning objectives. Assets Under Management As of December 31, 2022, NAMCOA manages $236,043,677 of investment assets. The breakdown on assets is as follows: $213,427,048 is managed on a discretionary basis representing 225 accounts and $22,616,629 is managed on a non-discretionary basis, representing 26 accounts.