Chelsea Counsel Company (“Chelsea”) is an SEC-registered investment adviser with its principal place of business located in Los Angeles, California. Chelsea began conducting business in 1971. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).
• Frederick John Ruopp, Jr., Chairman Chelsea offers the following advisory services to our clients: INDIVIDUAL PORTFOLIO MANAGEMENT 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. We manage these advisory 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
• Securities traded over-the-counter
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Mutual fund shares
• United States governmental securities
• Options contracts on securities 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. EQUITY - BALANCED MANAGEMENT The equity investment philosophy of Chelsea is to build portfolios using large capitalization high quality issues with the prospect of above average growth and price/earnings multiples at or below the general market, typically referred to as value investing. Our objective is to achieve consistent total rates of return which reflect the needs of the clients, and a dedication to preservation and sustained growth of capital. Portfolios are structured with industry leaders having good historical records, above-average consistency of earnings and dividends along with intended rates of return. Occasionally a smaller company will be recognized as presenting a superior opportunity and included. Identifying and forecasting change within sectors of the economy and with specific industry groups while establishing suitable price/earnings ratios before the market adjusts is central to our management style. FIXED INCOME MANAGEMENT Preservation of capital and the compounding of positive returns are the foundation of fixed income management. Experience has demonstrated over many periods that strategies which employ substantial maturity risk are successful only briefly. The negative

returns produced as interest rates and volatility increase then tend to overwhelm the positive results achieved earlier. Interest rate forecasting is an important element as is commitment made to the strongest grade credit ratings. At Chelsea, it is our belief that optimal results are obtained by correctly forecasting the direction of interest rates and staying with high quality securities. Yield curve and quality spread analysis along with management of duration to moderate maturity risk are also important contributors to positive performance. We have a long history managing tax – exempt municipal bonds. Individuals and insurance companies are the primary clients. These portfolios can be solely constructed in a single state, or to maximize the after-tax effect, they may encompass all fifty states plus Puerto Rico for the purpose of diversification. We manage these advisory 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. Through personal discussions with the client in which the client's goals and objectives are established, we determine if the model portfolio is suitable to the client's circumstances. Once we determine the suitability of the portfolio, the portfolio is managed based on the portfolio's goal, rather than on each client's individual needs. Clients, nevertheless, have the opportunity to place reasonable restrictions on the types of investments to be held in their account. Clients retain individual ownership of all securities. 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
• Securities traded over-the-counter
• Foreign issuers
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Mutual fund shares
• United States governmental securities
• Interests in partnerships 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. To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, we will: 1. send quarterly written reminders to each client requesting any updated information regarding changes in the client's financial situation and investment objectives; 2. at least annually, contact each participating client to determine whether there have been any changes in the client's financial situation or investment objectives, and whether the client wishes to impose investment restrictions or modify existing restrictions; 3. be reasonably available to consult with the client; and 4. maintain client suitability information in each client's file. AMOUNT OF MANAGED ASSETS As of March 31, 2023, Chelsea was actively managing $471,739,878 of clients' assets. Of these assets, $469,666,391 were managed on a discretionary basis and $2,073,487 were managed on a non-discretionary basis.