Firm Description Saxony Capital Management, LLC (“SCM”) is a Missouri company registered with the SEC as an investment advisor. SCM also maintains investment advisor registration in various other states as required by applicable law. SCM has been in business since September 2002. Principal Owners The principal owner of SCM is Saxony Financial Holdings, LLC. Types of Advisory Business SCM offers the following types of advisory services: 1. SCM – Asset Management Accounts (“AMAs”) 2. Financial Planning 3. Third Party Advisory Services 4. Third Party Advisory Annuity Services 5. Other Services 6. Assets Under Advisement An Advisory Client’s Account may be terminated at any time by SCM or by the Advisory Client by giving immediate written notice or verbal notice of such termination to the other party. In the event of termination, a pro rata refund of management fees prepaid by the Advisory Client to SCM (less any charges or other expenses owed) will be made from the effective date of termination through the end of the then-current billing period. SCM delivers important messages in clients Pershing statements, sent via email, or sent to the Client’s portal available through Orion Advisor Services. The messages include but are not limited to: Annual Offer for the SCM Firm Brochure, Privacy Policy, Form Client Relationship Summary and others. Clients will receive statements at a minimum quarterly. If there is activity the statements will be sent monthly. This method of communication is combined with notifications through electronic communication to the client’s email which was provided to SCM in the account opening documents. Additionally, SCM will contact the advisory client through the physical mail. 1. SCM – AMAs The AMAs offer asset monitoring, management and trade execution services to the Advisory Client. The AMAs will be charged an advisory fee, which covers investment advice, account monitoring and other services provided by SCM. Separate transaction charges will be charged by Saxony Securities, Inc. (“SSI”) and received by SSI for the execution of trades through SSI, a Broker-Dealer affiliated with SCM. The Advisory Client will grant discretionary authority to the SCM Investment Advisor Representative (the “IAR”) to manage securities in the AMAs, such as; no-load mutual funds, mutual funds offered at Net Asset Value (“NAV”), stocks, bonds, options and eligible variable annuities. In consideration for handling and servicing the AMAs, the Advisory Client will pay to SCM a management fee on a quarterly basis, in advance, in accordance with the applicable schedule noted. A discretionary account allows the IAR the authority to purchase and sell investments without prior authorization of the client to do so. The amount of the transaction, date and time is also included. Discretionary accounts can only be under a registered Investment Advisory firm such as SCM. Broker Dealers may not have discretionary authority for an asset-based fee. When a client and IAR 2. Financial Planning SCM does charge hourly or flat fees for financial planning. Advisory Client is sent an invoice either before or after the service is provided. Financial planning includes retirement and investment planning and includes but is not limited to the following services: fact finding, balance sheet analysis, income statement analysis, cash flow analysis, net worth analysis, financial account review, income tax return review, engagement meetings. The minimum net worth for a client to participate for a plan is $100,000. SCM does charge hourly or flat fees for additional services. Additional services include but are not limited to: strategies to enhance cash flow and net worth; strategies to reduce income tax, investment tax, and estate tax; retirement income distribution strategies; analysis of current investment accounts; investment research; and assessment of risk tolerance and risk capacity. Retirement Planning: 1) Gather Suitability Information (Form required to be completed by the Advisory Client) 2) Complete Priority Planning Review (Form required to be completed by the Advisory Client) 3) Define goals and objectives 4) Calculate Net Worth 5) Evaluate current investments and life insurance while determining risk; will the current allocation meet the goals? 6) Determine expenses and income (current and future) 7) Propose to the Advisory Client a strategy for investments and a budget Investment Planning: 1) Gather Suitability Information (Form required to be completed by the Advisory Client) 2) Complete Priority Planning Review (Form required to be completed by the Advisory Client) 3) Define goals and objectives 4) Calculate Net Worth 5) Evaluate current investments and life insurance while determining risk; will the current allocation meet the goals? 6) Propose to the Advisory Client a strategy for investments and a budget The following examples explain the payment and services for Financial Planning for each payment method, hourly or flat fee. Advisory Client may consider paying by the hour when a financial plan includes one of the following; retirement or investment planning. Since the amount of information required

to be collected is limited to only one person, the amount of time devoted on the financial plan could be less, so the Advisory Client may be better suited to pay hourly. This time allotted for the individual may be 2 to 3 hours. A flat fee financial plan is the other option for an Advisory Client such as a married couple or family since their plan may have more components/information in the plan. The financial plan could include both retirement and investment planning. This plan will require more time to gather information since more than one individual is involved, so a flat fee payment may be a better option. The amount of time allotted on all meetings/information gathering/Advisory Client education time could range from 4 to 6 hours. A fixed fee is determined by the Advisory Client and the IAR at the time of the initial consultation. The Advisory Client may terminate the agreement at any time. The following example shows how the flat fee for a more complex plan is determined for a family of four: Retirement Plan: Father and Mother, 3 hours Investment Planning: Father and Mother, 2 hours, Investment planning: Two children, 1 hour. Also included in this plan is the initial meeting, any additional calls or meetings before the final meeting, which at that time the financial plan is discussed. SCM does offer consulting services for retirement plans. In addition to these, SCM consulting services are available to clients that are trustees or other fiduciaries to retirement plans, such as 529, 401(k), 457(b) and 401(a) plans. 3. Third Party Advisory Services SCM maintains selling agreements with various other registered investment advisers to offer their advisory services. For detailed information, the Advisory Client should consult the separate disclosure brochure provided to them at account opening. SCM will perform the due diligence review on each third-party advisor. SCM IARs refer Advisory Clients to non-affiliated Investment Advisors to manage the Advisory Client’s assets. Investment Advisors include: AssetMark Investment Services, Inc., Lyons Wealth Management, Brinker Capital, Inc, Flexible Plan Investments Ltd., Cornerstone Select Advisors, LLC., Nationwide, Howard Capital Management, Brookstone Capital Management, Envestnet, SEI Investments, and KMC Wealth Management, Montal. 4. Third Party Advisory Annuity Services Third Party Advisory Annuity Services are offered through Nationwide and Prudential. 5. Other Services SCM IARs will charge a finder’s fee for additional services provided to Advisory Client(s). SCM IARs will provide family office services regarding delivery of checks to banks, mailing checks to fund companies, and other services offered as a holistic approach. 6. Assets Under Advisement The Client’s IAR monitors and evaluates those investments against the client’s Investment Profile and Objective. The IAR services include discussions on the holdings, asset allocation, market conditions, risk management, estate planning, cost basis, investment advice, future purpose and plans of the investments. The client will direct trades. Accounts included are 403B, 401k and accounts custodied with Pershing. Conflicts of Interest All compensation received by SCM in any payment form, such as fees, creates a conflict of interest. Clients have an option to choose a brokerage product which charges a commission (per transaction) with SCM’s affiliated broker dealer Saxony Securities, Inc. or an advisory product under SCM which charges an ongoing quarterly fee. In certain circumstances, the client will pay more to use a Third-Party Manager, (“TPM”) than the client will pay for having your IAR manage your account. The client needs to compare the total fees from a portfolio managed by the IAR and the TPM. The TPM’s total fee includes the TPM fee and your IAR’s referral fee. When the option is selected for the IAR to manage the clients’ account, the total fee charged by the advisor is on page 4 of the client agreement. Conflicts are addressed when the accounts are opened by a review of a SCM Compliance personnel. If a client account transfers in mutual fund share classes which are not the lowest class, SCM will convert the share class to the lowest cost share available. SCM continuously provides surveillance to client’s accounts activity to minimize violations and conflicts of interest. Also, accounts are reviewed on an annual basis for conflicts which includes the lowest cost share class available for the client. In addition, trades are reviewed daily to address any conflicts. Quarterly, the accounts are reviewed for correct billing. For example, if a client selects a position not to be billed, SCM can exclude individual positions from being billed. Trading in IAR’s own account is a Conflict of Interest. To address this conflict, all IARs trades are reviewed for: trading ahead of clients, receiving a better price than the client and trading against a client. These reviews are conducted by SCM compliance personnel. Assets under Management Saxony Capital Management, LLC total assets under management as of December 31, 2023 was $239,289,634. Of this amount $218,219,238 are discretionary and $21,070,396 are nondiscretionary.