Generation Capital Management, LLC (“GCM”) is a Rochester, NY-based independent, fee-based, SEC registered investment advisor firm. GCM was founded in 2003 by Scott Nasca. Mr. Nasca is the firm’s President, Chief Investment Officer and sole owner. As of December 31, 2023, GCM manages client assets of $ 916,589,883 including $128,616,969 on a discretionary basis and $ 787,972,914 on a non-discretionary basis. Business Focus GCM provides individualized portfolio and investment management and consulting services for individuals, high net worth individuals, charities, trusts and estates, corporations, retirement plans, municipal government entities and foundations. Initial Consultation Before we begin managing client portfolios, we engage a new or potential client in a pre-advisory consultation to gain better insight into the clients’ financial situation and expectations. During this consultation, we:
• Review the individual’s (or organization’s) goals, tax situation, financial needs, and limitations
• Gauge the individual’s (or organization’s) risk tolerance
• Conduct an analysis of current investment strategies and asset allocation By understanding each of these financial characteristics and communicating our investment philosophy, we can proceed with developing an investment strategy for the client and setting the expectations for our client-advisor relationship. Based on this conversation, the client typically selects a targeted allocation (fixed income, conservative balanced, balanced (fifty/fifty), growth balanced and equity). A large majority of our clients fit into one of these categories. However, we also take into consideration special situations such as restrictions on certain securities or asset classes, liquidity needs and tax situations when managing portfolios. We continuously manage the investments in the portfolios and the guidelines for each account are reviewed as needed with clients for any changes in the basic assumptions. Investment Advisory Services GCM provides discretionary portfolio management and retirement plan consulting services. GCM’s portfolio management services will involve us providing you with continuous and ongoing supervision over your specified accounts. You must appoint our firm as your investment adviser of record on specified accounts (collectively, the “Account”) held at qualified custodian. The Account consists only of separate account(s) held at the qualified custodian, under your name. The qualified custodian maintains physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. See Item 12 and Item 15 for more information. The Account is managed by us based on your financial situation, investment objectives and risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting, or holding securities, cash or other investments of the Account. We will need to obtain certain information from you to determine your financial situation and investment objectives. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however, we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. We are always reasonably available to consult with you relative to the status of your Account. You can impose reasonable restrictions on the management of your accounts, including the ability to instruct us not to purchase certain securities. It is important that you understand that we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you, or actions taken for you. We are not obligated to buy, sell, or recommend to you any security or other investment that we may buy, sell, or recommend for any other clients or for our own accounts. Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. 1) Portfolio Management. GCM offers active money management services for individuals, high net worth individuals, retirement plans, corporations, charities, institutions, trusts and estates, municipal government entities and foundations. a) Investment Philosophy. We believe the optimal strategy for long-term success requires extensive diversification across asset classes, sectors and styles. Our commitment to broad market representation by its very nature curtails risk and creates well-diversified portfolios. Because no single investment strategy can outperform over an extended period of time, we provide our clients with the diversification necessary to eliminate the risk associated with single-strategy or single-sector investing. b) Investment Strategy. In order to reduce risk for our clients, GCM is attracted to the broad diversification and variety of styles of management as well as the opportunity to allocate assets to the domestic and global markets. We combine an active investment approach with a disciplined investment strategy. We generally prefer a macroeconomic approach (top-down) to investing as precursor to individual security selection (bottom- up). Historically, certain sectors tend to do better than others during specific segments of the economic cycle. We combine the reliability of historical trends while factoring in current market conditions to set our targeted asset allocation. Our bottom-up analysis employs multiple analytic techniques including fundamental and technical analysis. c) Securities Used. Generally, client portfolios will be comprised of equity and fixed income securities, exchange traded funds (ETFs), and closed-end funds (CEFs), depending on the client’s strategy. For its Plan Sponsor clients, GCM may also use open-end mutual funds. For the portion of the clients' portfolio invested in open-end mutual funds and closed- end funds, the client generally pays two advisory fees. First, the client pays a standard quarterly fee on the market value of total assets managed by GCM which can include assets in closed-end and open-end funds. Second, there is a management fee paid at the fund level which is deducted from the fund’s net asset value. Likewise, other operating expenses are automatically deducted at the fund level. GCM has an active policy of monitoring the expense ratios of the registered investment companies to determine their size and appropriateness. i) About Equity Securities: Equity securities are an instrument that signifies a position in a corporation and represents a claim on its proportional share in the corporation’s assets and profits. Types of equity securities include, for example, common stocks, preferred stocks, and real estate investment trusts (REITs). ii) About Fixed Income Securities: Fixed-income securities pay interest, dividends, or distributions at a specified rate. The rate may be a fixed percentage of the principal or may be adjusted periodically. In addition, the issuer of a fixed-income security must repay the principal amount of the security, normally within a specified time. Types of fixed income securities include, for example, treasury securities, government securities, and corporate debt securities. iii) About Exchange Traded Funds (ETFs): An ETF is a fund that tracks an index, sector, or other asset, but which can be purchased or sold on a stock exchange the same way a regular stock can. iv) About Closed-End Funds (CEFs): Closed-end investment companies are publicly traded on the New York and American Stock Exchanges. Frequently, the selling price on the exchange or market value price is below the fund's net asset value and therefore, represents an undervalued or inefficiently priced security. The discount to net asset value is one of the most important criteria for selecting closed-end funds. The effect of the discount often negates the additional expense paid at the fund level and provides the opportunity for higher returns over time than constructing a portfolio of individually purchased investments. d) Portfolio Targets. The table on the next page shows the various portfolio allocations chosen by the majority of GCM clients. Each allocation seeks to maintain a percentage of equity and/or fixed income instruments in the portfolio. These targets can vary by ±15% based on market conditions. GCM increases exposure to equity markets and/or fixed income markets when macroeconomic research suggests it is prudent to do so. In volatile markets, and while assets are being redeployed, GCM may have higher allocations to cash and/or short-term Treasuries while waiting for targeted prices to be hit. Allocation

Targeted Percentage of Portfolio (Equity) Targeted Percentage of Portfolio (Fixed Income) Equity 100% 0% Growth Balanced 70% 30% Balanced 50% 50% Conservative Balanced 30% 70% Fixed Income 0% 100% GCM provides an investment advisory service known as "Cash Investment Management Service" as well. GCM also provides an additional service for accounts that may be held at a custodian that is not directly accessible by GCM (“Held Away Accounts”), but where we do have discretion. This service is for clients that have accounts they would like us to manage, but for some reason or another, the account can’t be moved. These are typically, but not limited to, 401(k) and similar retirement- plan participant accounts. Through an arrangement with Pontera Solutions, Inc. we are able to gain access and facilitate management of these held away accounts using the Pontera Order Management System. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link is provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is/are connected to the platform, GCM will review the current account allocations. When deemed necessary, we will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. GCM will periodically review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, using different tools as necessary. While Pontera Solutions Inc. asserts that it has implemented cybersecurity measures to protect your information, it is important to recognize the inherent risks of sharing your account credentials. It is crucial to acknowledge that no cybersecurity system is impervious to risk. In the event of a cybersecurity breach involving Pontera Solutions Inc., there is a possibility that your retirement plan participant account credentials could be exposed. Moreover, the sharing of login details with a third party, such as Pontera Solutions Inc., may contravene the terms-of-use of the online platform associated with your retirement plan participant account(s), potentially leading to service providers associated with those accounts disclaiming liability to you for any unauthorized transactions. This is a critical consideration as it might limit your recourse in the event of unauthorized access to your account. We recommend that you check the terms-of-use of the specific online platform(s) associated with your retirement plan participant account(s) with respect to this issue. In light of these considerations, Pontera Solutions Inc. posted a "Client Cyber Protection Pledge," which is available for review at https://pontera.com/client-protection-pledge. We strongly advise you to review this pledge along with the Subscription Agreement, Terms & Conditions, and Privacy Policy of Pontera Advisors Solutions, Inc. to understand the scope of their actual contractual obligations. Furthermore, it is essential to consult with your legal counsel to assess the risks associated with this arrangement and the enforceability of Pontera's pledge in protecting your interests. You are under no obligation to retain us to manage your retirement plan participant account(s). Important Disclosure for Retirement Plan Account & Individual Retirement Account Clients: When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Investors considering rolling over assets from a qualified employer-sponsored retirement plan (“Employer Plan”) to an Individual Retirement Account (“IRA”) should review and consider the advantages and disadvantages of an IRA rollover from their Employer Plan. A plan participant leaving an employer typically has four options (and may engage in a combination of these options): (1) Leave the money in the former employer’s plan, if permitted; (2) Rollover the assets to a new employer’s plan (if available and rollovers are permitted); (3) Rollover Employer Plan assets to an IRA; or, (4) Cash out the Employer Plan assets and pay the required taxes on the distribution. At a minimum, Investors should consider fees and expenses, investment options, services, penalty-free withdrawals, protection from creditors and legal judgments, required minimum distributions, and employer stock. We encourage you to discuss your options and review the above-listed considerations with an accountant, third-party administrator, investment advisor to your Employer Plan (if available), or legal counsel, to the extent you consider necessary. We have an economic incentive to encourage investors to rollover Employer Plan assets into an IRA managed by us, as we will earn fees as a result. 2) Retirement Plan Consulting. GCM also provides consulting services to retirement plan sponsors who utilize mutual funds as investment choices for plan participants. GCM provides this service to both non-ERISA and ERISA Plans. GCM does not act as, or assume the duties of, a trustee or the Plan Administrator. For the large majority of retirement plan clients, GCM has no discretion over the investment of Plan assets or the management, administration or any other aspect of the Plan. GCM offers the following Retirement Plan Consulting Services: a) Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client shall have the final decision-making authority regarding the initial selection, retention, removal, and addition of investment options. b) Assist the Client with the selection of a broad range of investment options. c) Assist the Client in the development of an investment policy statement (IPS). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement. d) Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain or remove and replace investment options. e) Meet with Client on a periodic basis to discuss the reports and the investment recommendations. GCM may also provide discretionary investment advice to these Plan Sponsor clients. This includes (1) developing an investment policy statement (IPS) for the Client, (2) selecting a broad range of investment options consistent with ERISA Section 403(c) and the regulations thereunder, and (3) providing ongoing and continuous discretionary investment management with respect to the asset classes and investment alternatives under the Plan in accordance with the IPS. Under this authority, GCM may remove and replace the investment alternatives available under the Plan in its discretion. As part of our contractual relationship with our Plan Sponsor clients, GCM may in some instances provide services to the employees of employer-sponsored retirement plan clients that generally consist of educational meetings on saving and investing for retirement, and the investment alternatives available under the Plan. GCM does not handle plan administration, recordkeeping, and other actuarial/legal matters. However, we may provide a review of the service providers for each of these areas and/or provide referrals. 3) Financial Planning Services. Additionally, GCM offers standalone financial planning services to its clients under the working name “genPOWERMENT” pursuant to a written agreement. These services are provided at varying levels depending on the nature and complexity of the client’s situation. The planning or consulting may encompass one or more areas of need, including, but not limited to financial goal setting, debt management, estate planning, cash flow and budgeting, education funding and retirement planning. All financial planning recommendations are based on information gathered through any of the following: client questionnaires, emails and telephone discussions, and the scope of the relationship can only be as in depth as the information that they provide to GCM.