ITEM 5 - ADDITIONAL COMPENSATION .................................................................................................... ii ITEM 6 - SUPERVISION .............................................................................................................................. ii DAVID A. HORVITZ, CFP® .................................................................................................................... iii ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ...................................................... iii Professional Designations ................................................................................................................... iii ITEM 3 - DISCIPLINARY INFORMATION .................................................................................................... iv ITEM 5 - ADDITIONAL COMPENSATION ................................................................................................... iv ITEM 6 - SUPERVISION ............................................................................................................................. iv JAMES M. WHITING, CFP® ................................................................................................................... v ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ....................................................... v Professional Designations .................................................................................................................... v ITEM 3 - DISCIPLINARY INFORMATION .................................................................................................... vi ITEM 5 - ADDITIONAL COMPENSATION ................................................................................................... vi ITEM 6 - SUPERVISION ............................................................................................................................. vi PAUL MATHESON ............................................................................................................................. vii ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ..................................................... vii Cheviot Value Management Brochure Revised May 23, 2024 6 ITEM 3 - DISCIPLINARY INFORMATION ................................................................................................... vii ITEM 5 - ADDITIONAL COMPENSATION .................................................................................................. vii ITEM 6 - SUPERVISION ............................................................................................................................ vii PRIVACY NOTICE ............................................................................................................................... A Cheviot Value Management Brochure Revised May 23, 2024 7 Description of Advisory Firm Cheviot Value Management, LLC (“CVM,” “we,” “our,” or “us”) is a privately owned limited liability company headquartered in Beverly Hills, CA. Frederic G. Marks and Nancy J. Marks founded CVM in 1974. In 1985, the firm transitioned to investment management and became registered with the U.S. Securities and Exchange Commission in 1985. David A. Horvitz and Darren C. Pollock assumed control of the firm in January 2013 upon the Marks’ retirement. Fiduciary Duty Registered investment advisers are considered fiduciaries under federal law. Our fiduciary duty carries with it an obligation to act in the best interest of our clients pursuant to a relationship of trust and confidence. It encompasses a duty of care and a duty of loyalty. Duty of Care The duty of care includes, among other things, 1. the duty to provide advice that is in the best interest of the client; 2. the duty to seek best execution of a client’s transactions where the adviser has the responsibility to select broker-dealers to execute client trades; and 3. the duty to provide advice and monitoring over the course of the relationship. The duty to provide advice suitable to each client based on a reasonable understanding of the client’s objectives is a critical component of the duty of care. Providing suitable advice includes making a reasonable inquiry into the client’s financial situation, investment experience, and financial goals and then updating this information as necessary throughout the course of the relationship to reflect the client’s changing objectives over time and adjusting the advice we provide to reflect any changed circumstances. When CVM has the responsibility to select broker-dealers to execute client trades in discretionary accounts, we seek to trade such that the client’s total cost or proceeds in each transaction are the most favorable under the circumstances. In doing so, we consider the full range and quality of a broker’s services and so the determinative factor is not necessarily the lowest possible commission cost but whether the transaction represents the best qualitative execution. Moreover, we periodically and systematically evaluate the execution we receive on behalf of our clients. Our duty of care includes an obligation to provide advice and monitoring at a frequency that is in the best interest of the client, taking into account the scope of the agreed relationship. This scope is indicated by the duration and nature of the services as outlined in each client’s advisory arrangement and extends to all personalized advice provided to clients. Duty of Loyalty CVM adheres to a duty of loyalty where we seek to serve the best interests of our clients and never subordinate the interests of our clients to our own. Simply put, CVM cannot place its own interests ahead of the interests of our clients. In observance of this duty, we must make full and fair disclosure to clients of all material facts relating to the advisory relationship. Further, we also seek to eliminate or at least expose through full and fair disclosure all conflicts of interest which might incline CVM, consciously Cheviot Value Management Brochure Revised May 23, 2024 8 or unconsciously, to render advice that is not disinterested. We believe that in order for disclosure to

be full and fair, it should be sufficiently specific so that each client is able to understand the material fact or conflict of interest and make an informed decision whether to provide consent. Consequently, we provide this ADV 2A brochure to all prospective clients at or before entering into a contract so that they can use the information within to decide whether or not to enter into an advisory relationship. Advisory Services Offered CVM offers the following services to advisory clients: Investment Management Services CVM provides continuous and regular investment supervisory services on a discretionary basis. Darren C. Pollock, David A. Horvitz, and James M. Whiting have the ongoing responsibility to select investments CVM purchases or sells in client accounts. CVM will primarily utilize the following investment types when making purchases in client accounts: 1. Equity securities, including stocks and foreign securities listed on US exchanges (ADRs) or foreign exchanges (ordinaries) 2. Fixed income securities, including corporate and government bonds 3. Municipal securities 4. Exchange traded funds (ETFs) 5. Money market funds and other cash equivalents Depending on the client’s individual investment objectives and needs, many portfolios further include, as CVM deems appropriate: 1. Securities with equity and debt characteristics, including convertible bonds, preferred stocks or other preferred securities 2. Mutual funds* 3. Closed-end funds 4. Master limited partnerships (MLPs) *Mutual funds are generally utilized only in special situations, including but not limited to seeking diversification in smaller accounts or accessing certain securities in the fund’s underlying holdings that would otherwise be difficult to obtain. CVM may also occasionally utilize additional types of investments at our discretion. We describe the material investment risks for many of the securities that we utilize under the heading Specific Security Risks in Item 8 below. Limitations on Investments In some circumstances, CVM’s advice may be limited to certain types of securities. Limitation by Plan Sponsor/Employer In the event CVM is managing assets within a retirement plan such as 401(k), 403(b), QRP or other employer plan, CVM is limited to those investment providers and investment options chosen by the plan Cheviot Value Management Brochure Revised May 23, 2024 9 administrator. Similarly, when we provide services to participants in an employer-sponsored plan, the participant may be limited to investing in securities included in the plan’s investment options. Therefore, CVM can only select investments to the client from among the available options and will not invest the client’s account in other securities, even if there may be more suitable options elsewhere. Mutual Fund Limitations Generally, CVM limits mutual fund selections to no load funds or load-waived equivalents. Limitation by Client CVM may also limit advice based on certain client-imposed restrictions. For more information about the restrictions clients can put on their accounts, see Tailored Services and Client Imposed Restrictions in this Item below. Financial Planning Services CVM provides complimentary financial planning services as part of our overall investment management services at a client’s request or for a separate fee to non-investment management clients, as described below. Clients receive a written financial plan providing the client with detailed analyses and recommendations designed in an effort to help them achieve their stated financial goals and objectives. In general, we seek to address all or part of the following areas in the financial plan:
• Goals and objectives
• Net worth
• Cash flow planning
• Tax planning review
• College funding
• Risk management and insurance planning
• Retirement planning
• Investment planning
• Estate planning CVM gathers information through in-depth personal interviews and document requests. Information gathered generally includes a client’s current financial status, future life goals, and attitudes towards risk. Related documents supplied by the client are carefully reviewed by CVM, and a written report is prepared. Should a client choose to implement the recommendations contained in the plan, CVM suggests the client work closely with his/her attorney, accountant, insurance agent, mortgage broker, and/or investment adviser. Implementation of financial plan recommendations is entirely at the client’s discretion. Clients may choose but are not required to have CVM assist with financial plan implementation, including investment management services. Fees for investment management and stand-alone financial planning services are described below in Item 5 – Fees and Compensation. Clients that choose to utilize CVM for financial plan implementation should keep us informed of any changes to their financial situation so that we can determine if corresponding adjustments to the financial plan are necessary. Cheviot Value Management Brochure Revised May 23, 2024 10 Budget Coaching Services CVM will support the client using a finance management software platform to assist the client with creating a personalized budget that includes categorizing expenses, creating categories, and planning for upcoming expenses. CVM’s support includes an initial consultation, budget construction and software orientation session, and three follow-up budgeting sessions. Additional blocks of four budgeting sessions are available for purchase as detailed under Item 5 – Fees and Compensation, below. Non-Managed Assets At its discretion, CVM may offer securities trading activities for cash and securities in a client’s non- managed account, acting as an intermediary between the client and the custodian of the non-managed account. We do not generally provide investment advice regarding a client’s non-managed assets or provide opinions as to the merits of any securities in non-managed accounts. We also do not make any judgments as to the appropriateness of assumed risk or suitability of any non-managed investment given the client’s situation. At our discretion, CVM may offer this service in consideration of the client’s other accounts that we manage. Tailored Services and Client Imposed Restrictions CVM makes individual investment decisions for clients based on a financial review and plan to help clients formulate realistic investment objectives. We then develop an investment policy in an effort to achieve those objectives. It is the client’s responsibility to keep us informed of any changes to his/her investment objectives. In limited circumstances, clients may request restrictions on the account, such as when a client needs to keep a minimum level of cash in the account or does not want us to buy or sell specific securities or security types in the account. CVM reserves the right to not accept and/or terminate management of a client’s account if we feel that the client-imposed restrictions would limit or prevent us from meeting or maintaining our overall investment strategy for the client. Wrap Fee Programs We do not provide portfolio management services to a wrap fee program. Assets Under Management CVM manages client assets in discretionary accounts on a continuous and regular basis. As of January 29, 2024, CVM had $822,972,737 in assets under our management.