Novick & Company Financial Group, LLC (“Novick”) is an SEC-registered investment adviser with its principal place of business located in Jackson, Wyoming. Novick & Company Financial Group, LLC began conducting business in 2009. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).
• Steven S. Novick
• Lisa A. Novick Novick & Company Financial Group, LLC offers the following advisory services to our clients: INVESTMENT SERVICES NOVICK WRAP FEE ADVISORY PROGRAM Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. Novick is the sponsor and sole investment manager of the Novick Wrap Fee Advisory Program (hereinafter the “Program”). A “wrap-fee” program is one that provides the client with advisory and brokerage execution services for an inclusive fee. The client is not charged separate fees for these respective components of the total service, though there may be additional costs related to fees and expenses charged by mutual funds and exchange traded funds (ETFs) to their shareholders, exchange fees, transfer taxes, charges for transactions executed away from the Program’s directed broker, odd-lot differentials, fees for electronic data feeds and reports or certain administrative fees for wire transfers or certificate issues. Transactions in Program accounts are effected 'net,' i.e., without separate commission charge to the client, and a portion of the wrap fee is generally considered as being in lieu of

commissions. In evaluating the Program, clients should consider therefore that, depending upon the level of the wrap fee charged, the amount of portfolio activity in the client's account, the value of custodial and other services which are provided under the arrangement, and other factors, the wrap fee may or may not exceed the aggregate cost of such services if they were to be provided separately and if Novick were to negotiate commissions and seek best price and execution of transactions for the client's account. For more information regarding the Program, including the fee schedule and other important information, clients should refer to the disclosure document (Appendix 1) for the Program. We manage client accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• Equities
• Foreign issuers
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares
• United States governmental securities
• Options contracts on securities
• Real estate Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. AMOUNT OF MANAGED ASSETS As of 12/31/2023, we were actively managing $215,000,000 of client assets on a discretionary basis and no client assets on a non-discretionary basis.