REV 3/25/2024 Page 3 of 19 A. Description of Advisory Business and Ownership of LLFA - We are an investment management firm providing investment consulting as well as discretionary portfolio management services. Our typical clients are high net worth investors with a liquid net worth between one and fifty million US dollars. The firm was formed on June 19, 2013. The principal owner(s) of our firm are: LIVIAN & CO., LLC –an SEC registered investment adviser majority owned by Michael Livian. FRIDSONVISION, LLC – a firm owned by Martin Fridson B. Our Advisory Services - We provide two types of services to our clients: (i) Investment Supervisory Services (ii) Investment Consulting Services (iii) LivX Digital Investment Portfolios Program. DISCLOSURE FOR RETIREMENT INVESTORS Pursuant to the Employee Retirement Income Security Act ("ERISA"), and regulations under the Internal Revenue Code of 1986 (the "Code"), Livian & Co., LLC and individuals providing investment advice on our behalf will be deemed to be investment advice fiduciaries when we render individualized investment advice to retirement investors (a participant or beneficiary of a Plan with authority to direct the investment of assets in his or her account or to take a distribution, the beneficial owner of an IRA acting on behalf of the IRA, or a fiduciary of a Plan or an IRA) for a fee or other compensation, whether direct or indirect. While we are already fiduciaries for all of your advisory accounts under the Investment Advisers Act of 1940, we are required to acknowledge our fiduciary status under ERISA and the Code. (i) INVESTMENT SUPERVISORY SERVICES We manage advisory accounts on a discretionary and non-discretionary basis. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income). We will create a portfolio of preferred shares, common shares, debt securities as well as Exchange Traded Funds (ETF’s) no-load, load-waived, and front-load open-end and closed-end mutual funds. We may occasionally utilize listed option contracts to hedge investment portfolios or to generate income. We will allocate the client's assets among various investments taking into consideration the overall management style selected by the client.  We select debt securities based on any or all of the following criteria: issuer, credit rating, maturity of the security, price and yield, duration, liquidity of the security, and special features (i.e. embedded options).  We select common and preferred shares based on any or all of the following criteria: fundamentals of the company, valuation ratios (price-earnings, price-sales, price to book value ratio, dividend yield), and certain quantitative/technical metrics of the price of the shares.  We select ETFs and ETNs based on any or all of the following: geographic, sector and industry exposure, diversification in the underlying securities, size and liquidity of the instrument and expense ratio.  We select mutual funds based on any or all of the following criteria: the fund's performance history, the industry sector in which the fund invests, the track record of the fund's manager, the fund's investment objectives, the fund's management style and philosophy, and the fund's management fee structure. We also offer advice on a more limited basis for securities not recommended by LLFA but included in the client’s portfolio at the client’s request. In this situation, we will provide reporting services and we will advise the client on the merits of a particular security at the client’s request; however, we will not monitor such investments, nor will LLFA take any action regarding the security, even in extreme market conditions, unless contacted by the client and specifically instructed as to the appropriate action to take. (ii) INVESTMENT CONSULTING SERVICES REV 3/25/2024 Page 4 of 19 We also provide consulting services, in which we may be engaged by a client to provide advice on such areas as asset allocation, review of existing investments and suggestions for future investments, and structuring of investment portfolios. (iii) LivX DIGITAL INVESTMENT PORTFOLIOS PROGRAM We offer an automated investment program (the “Program” or “LivX Digital Investment Portfolios”) through which clients are invested in a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange-traded

funds (“Funds”) and a cash allocation. The client may instruct us to exclude up to three Funds from their portfolio. The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“CS&Co”). We use the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate the Program. We are independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). We, and not Schwab, are the client’s investment advisor and primary point of contact with respect to the Program. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. We have contracted with SPT to provide us with the Platform, which consists of technology and related trading and account management services for the Program. The Platform enables us to make the Program available to clients online and includes a system that automates certain key parts of our investment process (the “System”). Option 1) The System includes an online questionnaire that can help us determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that, if we use the online questionnaire, we will recommend a portfolio via the System in response to the client’s answers to the online questionnaire. Option 2) Based on information the client provides to us, we will recommend a portfolio via the System. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but we then make the final decision and select a portfolio based on all the information we have about the client. The System also includes an automated investment engine through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). We charge clients a fee for our services as described below under Item 5 Fees and Compensation. Our fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co. as part of the Program. Schwab does receive other revenues in connection with the Program. We do not pay SPT fees for the Platform so long as we maintain $100 million in client assets in accounts at CS&Co. that are not enrolled in the Program. If we do not meet this condition, then we pay SPT an annual licensing fee of 0.10% (10 basis points) on the value of our clients’ assets in the Program. This fee arrangement gives us an incentive to recommend or require that our clients with accounts not enrolled in the Program be maintained with CS&Co. The clients enrolled in the LivX Digital Investment Portfolios invest in a select portfolio of exchanged traded funds, researched by us, and cash. For most other LLFA clients we typically invest in income-oriented individual securities. The type of investments in the LivX Program may be materially different from those of a typical client of ours that uses our investment supervisory services. C. Individual Client Needs and Restrictions - We provide advice to clients regarding the investment of their funds based on their individual needs. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. REV 3/25/2024 Page 5 of 19 Portfolio weighting between funds and market sectors will be determined by each client's individual needs and circumstances. Clients will have the opportunity to place reasonable restrictions on the types of investments, which will be made on the client's behalf. Clients will retain individual ownership of all securities. D. Wrap fee programs – This item is not applicable; we do not participate in wrap fee programs. E. Assets Under Management – The asset under management (AUM) of our firm as of February 29, 2024 are: Type AUM ($mil) Discretionary 79.9 Non-Discretionary 2.2 Total RAUM 82.1