A Oliver Capital Management, Inc., (“OCM” “we” and “Advisor”) is a Washington corporation registered as an SEC regulated investment advisor under the Investment Advisers Act of 1940, with its principal place of business located in Seattle, Washington. OCM began conducting business as an independent investment advisory firm registered in the State of Washington in 2003. The principal owner and advisor is Mark K. Oliver, President and Principal Shareholder. Our investment advisory services are driven by and coordinated with each Client’s individual financial goals. Our approach uses broadly diversified portfolios using indexed Exchange Traded Funds (ETFs) and a systematic strategy to manage investments. We follow strict fiduciary standards, putting our Clients’ interests before our own and seeking to avoid conflicts of interest with our Clients. We are compensated only by our Clients. B We provide Comprehensive Wealth Management Services to our Clients. Wealth Management Services involves providing advice to Clients on the most effective investment strategies given the particular Client’s personal and business goals. Once the Client agrees to an investment strategy, we will take the steps necessary to implement such strategy. OCM utilizes Fidelity Institutional (FI) and Schwab Institutional (SI) as third-party custodians for Client assets. Client assets are primarily invested in our Strategically Engineered Portfolio Program (SEPP), in accordance with our Statement of Investment Policy or a similar document utilized to establish our Client’s objectives and suitability. OCM also provides financial planning for its Clients as part of a Comprehensive Wealth Management (CWM) approach to serving its Clients. There is no minimum net worth requirement and no additional fees are charged for such financial planning services. The process and approach is described below. Financial Plans: 1. Our financial planning process includes gathering all information necessary to provide Client with a comprehensive written

financial plan, taking into account both the assets and liabilities associated with each Client’s personal balance sheet. The CWM written analysis may address one or more of the following topics of interest:  Retirement planning;  Asset allocation strategies;  Education planning;  Estate planning;  Tax mitigation suggestions;  Business succession planning; and  Insurance recommendations (i.e., life, disability, long-term care, umbrella). In addition to Client assets and liabilities, the CWM analysis provided by OCM, also takes into consideration the risk tolerances, goals and objectives as described by Client in the CWM Questionnaire. The CWM written analysis provided by OCM summarizes the area(s) of weakness in one’s financial plan and recommends appropriate solutions. 2. OCM will work with Client’s attorney and/or accountant in reaching agreement on solutions, as well as assisting those advisors in completion of applicable documents and the implementation of agreed upon strategies. OCM is not responsible for attorney or account fees charged to Client as a result of the above activities. 3. The Comprehensive Wealth Management Plan is typically reviewed on a regular basis based on individual circumstances. 4. If the Client so chooses, OCM will research and assist in acquisition of appropriate investment and insurance products that best solve stated Client objectives. OCM will typically monitor the ongoing performance of those products to ensure their continued role as appropriate financial assets/strategies. C All transactions in the account shall be made in accordance with the directions and preferences provided to OCM by the Client. Client will execute instructions regarding OCM’s trading authority as required by each custodian. D We do not participate in or sponsor any wrap-fee programs. E We manage $254,872,633 of Client assets on a nondiscretionary basis and $34,284,953 of Client assets on a discretionary basis. These amounts were calculated as of December 31, 2022.