Topturn provides investment management, wealth management, financial planning and consulting services. Prior to engaging Topturn to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with Topturn setting forth the terms and conditions under which Topturn renders its services (collectively the “Agreement”). Topturn has been in business as a Registered Investment Adviser with the SEC since September 15, 2009. Dan Darchuck and Greg Stewart are the principal owners of Topturn. Topturn has $160,024,000 in regulatory assets under management as of December 31, 2023. Of this total amount, $141,130,000 are managed on a discretionary basis, $18,894,000 managed on a non-discretionary basis. Topturn also has an additional $45,438,000 of assets under advisement. This Disclosure Brochure describes the business of Topturn. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of Topturn’s officers, partners, directors (or other persons occupying a similar status of performing similar functions), or employees, or any other person who provides investment advice on Topturn’s behalf and is subject to Topturn’s supervision or control. Wealth Management Services Clients can engage Topturn to manage all or a portion of their assets on a discretionary or non-discretionary basis. In addition, Topturn may provide clients with wealth management services which include a broad range of comprehensive financial planning and consulting services as well as discretionary and/or non-discretionary management of investment portfolios. As needed, Topturn will develop a comprehensive financial plan and/or provide ongoing financial planning services which take into consideration business planning, investment, insurance, retirement, education, estate planning, and tax mitigation planning and cash flow needs of the client. Topturn primarily allocates clients’ investment management assets among independent investment managers (“Independent Managers”), exchange-traded funds (“ETFs”), and individual debt and equity securities. In addition, where appropriate, Topturn may recommend that clients who are “accredited investors” as defined in Rule 501 under the Securities Act of 1933, as amended, invest in private placement securities, which may include debt, equity, and/or pooled investment vehicles when consistent with the clients’ investment objectives. Topturn also provides advice about any type of investment held in clients’ portfolios. Topturn also renders non-discretionary investment management services to clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans, and/or 529 Plans or other products that may or may not be held by the client’s primary custodian. In so doing, Topturn either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. Topturn tailors its advisory services to the individual needs of clients. Topturn consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. Topturn ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify Topturn if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon Topturn’s management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in Topturn’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Financial Planning, Pension and Other Consulting Services Topturn provides its clients with a broad range of comprehensive financial planning, pension and other consulting services. These services include non-investment related advice as well as business sale, succession planning, intra-family continuity, pension design, charitable and other tax mitigation strategies. In performing its services, Topturn is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. Topturn recommends the services of itself, its supervised persons, in their individual capacities, as licensed insurance agents /or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Topturn recommends its own services or those of its affiliates. The client is under no obligation to act upon any of the recommendations made by Topturn under a financial planning or consulting engagement or to engage the services of any such recommended professional, including Topturn itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of Topturn’s recommendations. Clients

are advised that it remains their responsibility to promptly notify Topturn if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Topturn’s previous recommendations and/or services. Use of Independent Managers As mentioned above, Topturn recommends that certain clients authorize the active discretionary management of a portion of their assets by and/or among certain Independent Managers, based upon the stated investment objectives of the client. The terms and conditions under which the client engages the Independent Managers are set forth in a separate written agreement between Topturn or the client and the designated Independent Managers. Topturn renders services to the client relative to the discretionary and/or non-discretionary selection or recommendation of Independent Managers. Topturn also monitors and reviews the account performance and the client’s investment objectives. Topturn receives an annual advisory fee which is based upon a percentage of the market value of the assets being managed by the designated Independent Managers. When recommending or selecting an Independent Manager for a client, Topturn reviews information about the Independent Manager such as its disclosure brochure and/or material supplied by the Independent Manager or independent third parties for a description of the Independent Manager’s investment strategies, past performance and risk results to the extent available. Factors that Topturn considers in recommending an Independent Manager include the client’s stated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Managers, together with the fees charged by the corresponding designated broker- dealer/custodian of the client’s assets, may be exclusive of, and in addition to, Topturn’s investment advisory fee set forth above. In addition to Topturn’s written disclosure brochure, the client also receives the written disclosure brochure of the designated Independent Managers. Certain Independent Managers may impose more restrictive account requirements and varying billing practices than Topturn. In such instances, Topturn may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Management of Collective Investment Vehicle Topturn is the general partner of Omnistrat Fund, LP (the “Private Fund”), which was formed to engage primarily in the business of investing and trading in securities. Interests in the Private Fund are privately offered pursuant to Regulation D under the Securities Act of 1933, as amended. The Private Fund currently relies on an exemption from registration under the Investment Company Act of 1940, as amended. Topturn has discretionary authority to determine the broker or dealer to be used by the Private Fund. The Private Fund’s investment objective is to achieve superior, risk-adjusted, long-term investment returns through employment of a multi-strategy quantitative directional strategy utilizing investments in individual equities, major debt and equity index funds, index futures and ETFs. Participation as an investor in the Private Fund is restricted to investors that are both qualified clients as defined in Rule 205-3 under the Investment Advisers Act of 1940 and “accredited investors” as defined in Rule 501 under the Securities Act of 1933, as amended. To the extent certain of Topturn’s individual advisory clients qualify, they will be eligible to invest in the Private Fund. A conflict of interest exists when Topturn recommends that its advisory clients invest in the Private Fund because of Topturn’s desire to promote the success of the Private Fund and because of the potential for Topturn to earn more compensation from managing the client’s assets through the Private Fund. Investment in the Private Fund involves a significant degree of risk. All relevant information, terms and conditions relative to the Private Fund, including the compensation received by Topturn, withdrawal rights, minimum investments, qualification requirements, suitability, risk factors, potential conflicts of interest, are set forth in the relevant confidential private offering memorandum, operating agreement and/or subscription agreement (collectively the “Offering Documents”), which each investor is required to receive and/or execute prior to being accepted as an investor in the Private Fund. Topturn will devote its best efforts with respect to its management of both the Private Fund and its individual client accounts. Given the above discussion relative to the objectives, suitability, risk factors, and qualifications for participation in the Private Fund, Topturn may give advice or take action with respect to the Private Fund that differs from that for individual client accounts. To the extent that a particular investment is suitable for both the Private Fund and certain individual client accounts, such investments will be allocated between the Private Fund and the individual client accounts pro rata based on the assets under management or in some other manner which Topturn determines is fair and equitable under the circumstances to all of its clients.