A. Firm Information CIM was established in May of 2007 as a Delaware limited liability company. CIM is 99% owned by its Chief Executive Officer (“CEO”), Andrew Clinton. B. Advisory Services CIM specializes in the management of tax exempt fixed income portfolios for individual investors, financial advisors and institutional investors in the form of separately managed accounts (“SMA”). Our investment philosophy focuses on maximizing our client’s after-tax total rate of return, over time, while achieving consistent, competitive yields, and reducing our client’s volatility experience. We do this using a research-based, diversified investment process, which focuses on three key decision criteria—duration, sector allocation and security selection. Certain SMAs may also invest in corporate debt, U.S. government securities or equity securities. The SMAs are customized to reflect and meet the unique investment requirements of the specific client, and actively managed to take advantage of any emerging investment opportunities in the market that best fit the client’s needs. CIM does not provide financial planning, estate planning, or insurance planning services. If requested by a client, CIM may provide limited consultation services on investment and non-investment related matters that are not included in the investment management process. Any such services would be offered exclusively on an unsolicited basis, for which CIM will not receive any additional fee or compensation. Clients are typically referred to CIM by other non-affiliated investment advisors (“Financial Advisors”). CIM may have a single sub-advisory investment agreement with the referring Financial Advisor, in the instance that the Financial

Advisor has full discretion over client assets, or a direct investment management agreement with the referred end client. In either instance, the referring Financial Advisor is typically CIM’s main point of contact for client portfolio updates and communications. The Financial Advisor maintains the end client relationship and is responsible for determining the suitability of CIM and its investment advisory services as described in the effective investment management agreements. C. CIM has the ability to customize its services to the individual needs of its clients. CIM does allow clients to impose reasonable restrictions on investing in certain securities or types of securities. These restrictions must be submitted in writing and approved by CIM prior to being implemented on the specified account. D. CIM does participate in wrap programs that are sponsored by non-affiliated entities and provides the same level of investment advisory services to these clients. For its investment advisory services CIM receives from the wrap program sponsor a portion of the all-inclusive wrap fee paid by the client to the wrap program sponsor. The wrap program allows clients to receive discretionary portfolio management services from any of the participating investment advisors, assistance in choosing the appropriate portfolio managers, trade execution services as well as custodial services for a single all-inclusive fee for these services offered by the wrap program sponsor. All assets at CIM are managed in a consistent fashion across the firm regardless of the source of the assets. E. CIM has $1,689,377,858 of assets under management as of December 31, 2022. All of CIM client’s assets are managed on a discretionary basis.