Gill Capital Partners is a SEC-registered investment adviser with its principal place of business located in Colorado. Gill Capital Partners began conducting business in 1983, registered with the State of Colorado as an investment adviser in 2004, and registered with the SEC as an investment adviser in 2006. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company). x OBW, LLC, Holding Company Gill Capital Partners offers the following advisory services to our clients: INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT Wealth Management Gill Capital Partners offers clients a wide range of investment services that includes money management, comprehensive financial planning, and tax planning and preparation. Clients can choose from an array of services that best fit their situation, each having a separate fee structure, or they can use EncompassSM, a bundled approach to managing their personal finances (described below). Our firm provides continuous advice to clients regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issuers
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares
• United States government securities
• Options contracts on securities
• Real Estate
• Private securities Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. ENCOMPASSSM Encompass is a comprehensive offering in which clients may utilize a suite of services for a single fee. Encompass includes wealth management, tax planning and preparation1, education planning2, retirement planning, estate planning3, insurance planning4, charitable giving, and cash management. 1Gill Capital Partners will prepare one form 1040 (federal return) and schedule(s) A, B, C, D, and E, and up to two state returns. If needed, we may prepare additional returns for the client and have the option to charge an additional fee as outlined in the fee schedule for Tax Planning and Preparation. 2Depending upon the client's situation, we may recommend that the client invest in a 529 plan. Clients should be aware that many 529 plans are considered load funds and pay a service fee and/or commission to the advisor. In this situation, we will not charge a management fee on such assets and will collect the commission or service fee instead. 3It is expected that the client would engage an attorney to prepare the legal documents related to estate planning. As such, any legal fees would be exclusive of the fee charged by Gill Capital Partners. We will coordinate planning efforts with the client's attorney. If the client does not have an attorney, we may recommend an attorney to assist the client. 4If during the planning process it is determined that a client needs insurance of any type, Gill Capital Partners will offer to assist the client in obtaining the recommended insurance. The client, however, is under no obligation to work with Gill Capital Partners and may work with the insurance agency of their choice. If Gill Capital Partners places any insurance business, we will receive a commission and such commission will be compensation received in addition to any fees paid by the client. Institutional Services Gill Capital Partners provides continuous investment advice and portfolio management to institutional clients, including but not limited to banks, credit unions, municipalities, special districts, and school districts. Through meetings with authorized representatives, and in some cases, the investment committee or board of directors, the needs and investment objectives of the institution are determined. Safety of principal and liquidity to meet financial obligations generally are the primary needs of most institutional clients. Gill Capital Partners then identifies investment strategies and specific investments that are consistent with the needs of the client and our understanding of current market conditions. Gill Capital Partners utilizes portfolio management software and Bloomberg to track and report portfolio performance, portfolio analysis, and cash flow analysis. We can provide portfolio reports monthly or quarterly as required by the client. Reports include Performance and Account Summary, Maturity Distribution, Investment Portfolio Detail, Purchase and Sales, Realized Gains and Losses, Interest and Expense, and Accrued Interest. Gill Capital Partners can also create custom reporting as required by the client. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., preservation of principal, income, liquidity), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issuers
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Mutual fund shares
• United States government securities
• Real Estate Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. Fund Advisory Services Gill Capital Partners serves as the Investment Manager of the Parliament Income Fund, LLC (the “Fund”), a Delaware Limited Liability company. Gill Capital Partners also acts as general partner of the Fund. Gill Capital Partners provides investment advice, administrative support, and marketing support to the Fund. The Fund’s confidential offering memorandum lays out the investment strategy, investor requirements, fees, and other terms of the Fund. Investors in the Fund (“Investors”) do not enter into an investment management agreement with Gill Capital Partners and are not considered advisory clients unless they have separately entered into an agreement with Gill Capital Partners for other services. Investors

may not impose restrictions on the Fund’s investment in certain securities or types of securities. However, Investors may be excused from a particular investment due to legal, regulatory or other constraints. This brochure is provided to the Investors and is also qualified in its entirety by the Fund’s offering memorandum, limited partnership agreement, and other governing documents (collectively, the “Offering Documents”). Gill Capital Partners’ role as Investment Manager to the Fund may create potential conflicts of interest. Gill Capital Partners and its employees may be motivated to recommend that clients invest in the Fund because the management fee Gill Capital Partners receives from the Fund is generally higher than the management fees clients pay for other services. Please see Item 10 for more information about how Gill Capital Partners addresses potential conflicts of interest. QUALIFIED RETIREMENT PLAN SERVICES Plan Design and Implementation Gill Capital Partners works with entities to design and implement a qualified retirement plan. This may include, but is not limited to, employee stock ownership plans, profit-sharing, money purchase, and 401(k)s. Clients may contract with Gill Capital Partners to perform administration, record-keeping, and tax reporting as it relates to the qualified plan. Plan Advising Plan advising consists of the following: Investment Policy Statement Preparation (hereinafter referred to as ''IPS''): We work with the client to determine an appropriate investment strategy that reflects the plan sponsor's stated investment objectives for management of the overall plan. Our firm then prepares a written IPS detailing those needs and goals, including an encompassing policy under which these goals are to be achieved. The IPS also lists the criteria for selection of investment vehicles as well as the procedures and timing interval for monitoring of investment performance. Selection of Investment Vehicles: We assist plan sponsors in constructing appropriate asset allocation models. We then review various mutual funds (both index and managed) to determine which investments are appropriate to implement the client's IPS. The number of investments to be recommended will be determined by the client, based on the IPS. Monitoring of Investment Performance: We review client investments at least quarterly, based on the procedures and timing intervals delineated in the Investment Policy Statement. Although our firm is not involved in any way in the purchase or sale of these investments, we supervise the client's portfolio and will make recommendations to the client as market factors and the client's needs dictate. Employee Communications: For pension, profit sharing and 401(k) plan clients with individual plan participants exercising control over assets in their own account (''self-directed plans''), we may also provide quarterly educational support and investment workshops designed for the plan participants. The nature of the topics to be covered will be determined by us and the client under the guidelines established in ERISA Section 404(c). The educational support and investment workshops will NOT provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations. We may, however, meet with plan participants on a one-on-one basis and provide individualized advice and tailored recommendations.
TAX PLANNING AND PREPARATION Gill Capital Partners has engaged various CPAs to provide tax planning and preparation for individuals and business owners. These services may be utilized through Encompass, or they may be provided to the client for a separate fee. Accounting services performed by these CPAs may be separate and distinct from our advisory services. We offer tax planning and preparation to client's enrollment in Encompass. FINANCIAL PLANNING Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients receiving this service receive a written report which provides them with a detailed financial plan designed to help them achieve their financial goals and objectives. In general, the financial plan can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax and spending for past, current and future years, then illustrate the impact of various investments on the client's current income tax and future tax liability.
• INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio.
• INSURANCE: We review existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals.
• DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including, as appropriate, living trusts, wills, estate tax planning, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law. We gather the required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, return objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or financial adviser. Implementation of financial plan recommendations is entirely at the client's discretion. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Investment recommendations made during the planning process are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issuers
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares
• United States government securities
• Options contracts on securities
• Real Estate
• Private securities Typically, the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. ADDITIONAL SERVICES Gill Capital Partners can provide the following additional services for a fee: portfolio accounting, business consulting, due diligence, development of investment policy statements, and attendance at board meetings. AMOUNT OF MANAGED ASSETS As of December 31, 2023, we were actively managing $717,903,721 of clients' assets on a discretionary basis. We were not managing any client assets on a non-discretionary basis. Our total regulatory assets under management on December 31, 2023, were $717,903,721