A. Capital Investment Management, Inc. (“Registrant”) is a corporation formed on April 16, 1998 in the State of Missouri. The Registrant became registered as an Investment Adviser Firm in June 1998. The Registrant is owned by David M. Garrison, Troy R. Schuster, and Matthew T. Shull. Mr. Schuster is the Registrant’s President. B. As discussed below, the Registrant offers to its clients (individuals, trusts, etc.) investment advisory services, and, to the extent specifically requested by a client, financial planning and related consulting services. INVESTMENT ADVISORY SERVICES The client can determine to engage the Registrant to provide discretionary or non- discretionary investment advisory services on a fee basis. The Registrant provides investment advisory services through a number of programs as set forth below. ASSET MANAGEMENT Co-Advisory Services WealthPort Capital Investment Management (CIM) participates, under a co-advisory relationship with Cambridge Investment Research Advisors, Inc. (CIRA), in fee-based services sponsored through CIRA’s WealthPort Wrap Programs. The wrap fee programs charge an inclusive fee, covering custodial, brokerage, and investment advisory services. WealthPort Wrap Programs encompass the Cambridge Asset Allocation Platform (CAAP®) and Unified Managed Account. A full and complete description of each Program is provided in the WealthPort Wrap Brochure. All investors participating in WealthPort Programs will be provided with and should review the WealthPort Wrap Brochure prior to investing. https://www.joincambridge.com/content/dam/joincambridge/documents/wealthport_wrap _brochure.pdf CAAP® The CAAP® program is a discretionary portfolio management solution offering access to multiple individual portfolio strategists. Each strategist offers a unique approach to investing and may offer multiple model portfolios. CIM IARs work with clients to identify an appropriate strategist(s) and model portfolio(s) based on individual circumstances, investment objectives, risk tolerance, and time horizon. Clients are provided an Investment Policy Statement (IPS) which confirms the selected strategist(s) and model portfolio(s), as well as the investment objective and time horizon. The IAR will meet with the client at least annually to review personal circumstances and investment objectives and confirm the appropriateness of the strategist(s) employed and model portfolio(s) utilized. CAAP® strategists are not affiliated with CIM or CIRA. Unified Managed Account A Unified Managed Account (“UMA”) offers you the ability to select multiple CAAP® strategies in one account. The UMA holds the investments recommended by each selected Strategist in a separate sleeve. Utilizing the proposal generation tools, the CIM IAR customizes the asset allocation models for you or alternatively, selects proposed asset allocations for types of investments fitting your profile and investment goals. CIM IARs then further customizes your portfolio by selecting the specific underlying investment strategies or investments in the portfolio to meet your needs. Cambridge Managed Account Platform (CMAP) Through the Cambridge Managed Account Platform (“CMAP”) CIM IARs will be responsible for determining investment recommendations and implementing transactions. The CIM IAR shall manage your account(s) in accordance with your individual needs, objectives and risk tolerance. These accounts are managed on either a discretionary trading basis or non-discretionary trading basis as agreed to by you and the CIM IAR. In order to have trading authorization on your account(s) the CIM IAR must be granted limited power of attorney over the account(s). The Cambridge Managed Account Platform (CMAP) is a flexible, low cost, advisor representative driven and controlled platform. CMAP allows rep-advisors to use a broad array of investment products, including individual general securities, load funds at NAV, no-load funds, bonds, etc. Cambridge rep-advisors can choose between two clearing firms: National Financial Services LLC (NFS), a Fidelity Investments® company, Pershing LLC, an affiliate of the Bank of New York Mellon. Both are members of FINRA/SIPC. FINANCIAL PLANNING AND CONSULTING SERVICES Generally, there is no extra charge to the fee-based clients of CIM for planning services. In addition, the Registrant’s representatives may implement securities transactions and/or insurance products for the client and earn commissions in their individual capacities as registered representatives of Cambridge. The Registrant’s representatives will gather information through interviews with the client on pertinent topics that may include: current financial status, assets and investments, current and future employment, future goals, attitudes toward risk, income needs, projected rates of return, inflation assumptions, social security assumptions, pension projections, inheritances, income distribution projections, dependent needs, estate topics, long term care planning, insurance planning, etc. Written plans may include any or all these topic areas. (See Written Retirement Plans) Written Retirement Plans Clients contracting for written retirement plans will receive a written plan prepared by the Registrant’s representatives. Retirement planning can include, but is not limited to, the following areas:
• Retirement Planning and Projections
• Retirement Feasibility Reports
• Retirement Income Distribution
• IRC Rule 72t Calculations
• Investment Portfolio Analysis
• Life Insurance Needs
• Long Term Care Needs
• Educational Planning Prior to engaging the Registrant to provide planning or consulting services, clients are generally required to enter into a Financial Planning Agreement with Registrant setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Registrant commencing services. If requested by the client, Registrant may recommend the services of other professionals for implementation purposes, including the Registrant’s representatives in their individual capacities as registered representatives of a broker-dealer and/or licensed insurance agents. (See disclosure at Item 10.C.1 to 10.C.2 ). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Registrant. Please Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against

the engaged professional. Please Also Note: It remains the client’s responsibility to promptly notify the Registrant if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services. MISCELLANEOUS Non-Investment Consulting/Implementation Services. To the extent requested by the client, the Registrant may provide consulting services regarding non-investment related matters, such as estate planning, eldercare planning, tax planning, insurance, etc. Neither the Registrant, nor any of its representatives, serves as an attorney or accountant, and no portion of the Registrant’s services should be construed as same. To the extent requested by a client, the Registrant may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance agents, etc.), including representatives of the Registrant in their separate registered/licensed capacities as discussed below. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Registrant. Please Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note: It remains the client’s responsibility to promptly notify the Registrant if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services.
• For households above $500,000 in AUM, the annualized advisor's fee include's tax planning and preparation in conjunction with Capital Tax and Consulting.Households above $1,000,000 in AUM qualify for a Living Trust, Will(s) or Power of Attorney documents by the Trust and Will Center or an approved Estate planning firm.
• No credit is due if client does not use these services. Independent Managers. The Registrant may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated independent investment managers in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager[s] shall have day-to-day responsibility for the active discretionary management of the allocated assets. The Registrant shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which the Registrant shall consider in recommending Independent Manager[s] include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. Please Note (Wrap/Managed Account programs). In the event that Registrant is engaged to provide investment management services as part of a wrap program not sponsored by the Registrant, Registrant will be unable to negotiate commissions and/or transaction costs. Under a wrap program, the wrap program sponsor arranges for the investor participant to receive investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Participation in a wrap program may cost the participant more or less than purchasing such services separately. In the event that Registrant is engaged to provide investment management services as part of an unaffiliated managed account program, Registrant will likewise be unable to negotiate commissions and/or transaction costs. If the program is offered on a non-wrap basis, the program sponsor will determine the broker-dealer though which transactions must be affected, and the amount of transaction fees and/or through commissions to be charged to the participant investor accounts. Client Obligations. In performing its services, Registrant shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify the Registrant if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services. Written Acknowledgement of Fiduciary Status When The Registrant provides 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. C. The Registrant shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, the Registrant shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on the Registrant’s services. D. Registrant does not sponsor a wrap fee program for its investment advisory services. However, Registrant is a participating investment adviser in certain unaffiliated wrap and managed account fee programs. Please Note: When managing a client’s account on a wrap fee basis, the Registrant shall receive as payment for its investment advisory services, the balance of the wrap fee after all other costs incorporated into the wrap fee have been deducted. E. As of December 2023, the Registrant had $ 425,863,045 in assets under management on a discretionary basis, and $ 0 in assets under management on a non- discretionary basis.