ETFidea was formed on June 13, 2002, and has been providing asset management services since inception. ETFidea is a wholly owned subsidiary of Diversified Capital Management, LLC. Diversified Capital Management, LLC is a brokerage firm offering its clients traditional brokerage services. The members of Diversified Capital Management, LLC, are also either Registered Principals of Cadaret, Grant & Co., Inc. and / or Members of Bowers & Company CPAs, PLLC. Diversified Capital Management, LLC, Cadaret, Grant & Co., Inc., Bowers & Company, LLC and the Applicant are all separate entities. ETFidea, through Diversified Capital Management has two principal owners, William Kriesel and Michael D’Avirro. The educational and professional backgrounds for Bill and Mike are as follows: William T. Kriesel - Born in 1964 B.S. - Accounting from Lemoyne College, Syracuse, NY 11/2007 - Present - Member - B&C Planning Services, LLC 01/2006 - Present - Bower's & Company, CPA's - Partner in the Tax and Financial Planning Department 08/2003 - Present - Member -ETFidea, LLC 08/2003 - Present - Investment Adviser Representative of ETFidea, LLC 10/1999 - Present - Registered Representative with Cadaret, Grant & Co., Inc. 11/1998 - Present - Registered Representative of Diversified Capital Management, LLC 07/1993 - 12/2005 - Partner in charge of Taxation - Grimaldi & Nelkin P.L.L.C Michael G. D’Avirro – Born in 1960 B.S. – Accounting from SUNY Oswego, Oswego, NY M.S. – Accounting from Syracuse University 5/1991 – Present – Bower’s & Company, CPA’s – Managing Partner 10/2015 – Present – Member of Diversified Capital Management, LLC 10/2015 – Present – Member of ETFidea, LLC 5 ETFidea, LLC is a Registered Investment Advisor with the Securities and Exchange Commission (SEC), and has multiple Investment Advisor Representative (IARs). ETFidea, LLC provides a variety of advisory services including, but not limited to, investment supervisory services, managing investment advisory accounts not involving investment supervisory services, and furnishing

investment advice through consultations not involving investment supervisory services. IAR(s) of the ETFidea may offer to provide investment advisory services to clients where custody of the account is maintained at Fidelity Investments, Pershing, LLC or other custodians. At a minimum, each client will receive confirmation of all trades, monthly statements of activity and balances, and quarterly consolidated appraisals with asset performance calculations. IAR's of the ETFidea may enter into solicitation agreements with various investment advisors or money managers that offer one or more services, such as money management or asset allocation. Under such agreements, the client pays a management fee to the advisory firm or money manager based on the amount of assets under management. ETFidea or its IARs are normally paid a fixed portion of the manager's fee as a solicitor agent, as outlined in the solicitation agreement between the ETFidea and the money manager, in exchange for introducing clients to the advisory firm. The Advisor and its IARs provide investment and portfolio management services where the advice provided is tailored to the specific needs and objectives of the client. We will, with the client, assess the risk tolerance of the client and recommend a portfolio that is within the risk tolerance range established and planned to meet the goals of the client. In implementing the portfolio, ETFidea or its IARs will primarily utilize Exchange-Traded Funds (ETF's), Individual Fixed Income Securities, or Mutual Funds. The Advisor or its IARs may include other security types it may deem prudent. Each IAR has their own investment strategy which they will disclose to their clients, and design portfolios to achieve their client's investment goals. IARs will select Pershing, LLC (Pershing) or Fidelity Brokerage Services LLC, (Fidelity) to act as custodian for the accounts. 6 As of December 31, 2020, ETFidea managed $336,455,000 of assets, of which $334,185,000 was on a discretionary basis and $2,270,000 was non-discretionary.