A. The Company Fleetwood Asset Management Ltd. is a privately-held New York corporation that has been providing investment advisory services since 2004 and has been registered with the SEC since May 2007. Throughout this disclosure brochure, the company is referred to as “Fleetwood”. The principal owner of Fleetwood is Joan M. Guccione. B. Advisory Services Fleetwood provides the following investment advisory services: Investment Management Services Fleetwood provides personalized investment management services which consists of giving continuous advice to a client or making investments for a client based on the individual needs of the client. Through personal discussions, during which a client’s goals and objectives are established, a client financial profile is developed to determine appropriate investments and levels of risk. The profile is developed as follows: 1. Gathering of client information. 2. Consultation with client to determine goals and objectives. 3. Review of basic financial data including overview of assets and liabilities, cash flow, tax situation, short-term events, long-term goals, risk management, and estate structures. 4. Identify the need for additional professional advice re: legal, tax, etc. Fleetwood will then create and manage a customized portfolio based on that profile. Fleetwood will allocate the client's assets among various investments based on the client’s risk tolerance. Fleetwood will create a portfolio principally comprised of no-load mutual funds and exchange traded funds (ETF’s). Each portfolio will be designed with the goal of meeting each client's individual needs. The mutual funds will be selected on the basis of any or all of the following criteria: the fund's performance history; the industry sector in which the fund invests; the track record of the fund's manager; the fund's investment objectives; the fund's management style and philosophy; and the fund's management fee structure. Clients will retain individual ownership of all securities. Fleetwood will manage advisory accounts on a discretionary basis only. Financial Consulting Services Occasionally, clients request consultation services in the areas of insurance, taxation, and general or overall financial management. In these instances, the specific services are agreed upon beforehand. An engagement letter is written specifying the exact nature of the services

and the estimated hours of services. C. Client Tailored Services and Client Imposed Restrictions Fleetwood offers a full range of investment advisory services which can be tailored to meet the specific needs of each client. In order to provide appropriately individualized services, Fleetwood will work with the client to obtain information regarding the client’s financial circumstances, investment objectives, overall financial condition, income and tax status, personal and business assets, risk profile and other information regarding the client’s financial and investment needs. Fleetwood will periodically review with clients their financial circumstances, investment objectives and risk profile. In order for Fleetwood to provide effective advisory services, it is critical that clients provide accurate and complete information to Fleetwood and inform the firm anytime such information needs to be updated or anytime there is a change in their financial circumstances, investment objectives and/or risk profile. Generally, clients are permitted to impose reasonable restrictions on investing in certain securities or types of securities in their advisory accounts, provided, however, that some restrictions may not be accommodated when utilizing Exchange Traded Funds, mutual funds or with respect to certain third-party products or services made available through Fleetwood. In addition, a restriction request may not be honored if it is fundamentally inconsistent with Fleetwood’s investment philosophy, runs counter to the client’s stated investment objectives, or would prevent Fleetwood from properly servicing client accounts. D. Wrap Fee Programs Fleetwood does not provide portfolio management services to a wrap fee program(s). Under a wrap fee program, advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and transaction services (e.g., execution of trades) are provided for one fee. This is different than traditional investment management programs whereby services are provided for a fee, but transaction services are billed separately on a per-transaction basis. E. Our Assets Under Management As of December 31, 2022, the total amount of client assets managed by Fleetwood is approximately $73,202,130. All of these assets are managed on a discretionary basis.