Fountainhead Capital Management, LLC (“Fountainhead,” “we,” “our,” “us”), doing business as “Fountainhead Advisors,” is an SEC registered investment adviser with its principal place of business located in Warren, NJ. Fountainhead provides financial planning, investment management, and pension consulting services to its clients. The firm has been registered as an investment adviser since March 2011 and is principally owned by Marc B. Rock, Scott H. Silver, and Joseph Halpern. These three owners also manage and control our advisory affiliates, Fountainhead AM, LLC, and Fountainhead Retirement Services LLC, and our insurance-licensed affiliate, Fountainhead Protection Strategies, LLC, through their collective equity positions. See Item 10 for additional information. Prior to engaging Fountainhead to provide any investment advisory services, clients enter into one or more written agreements with us (“Agreement”) that detail specific aspects of the relationship, including the services to be provided and the associated fees. Financial Planning Services Fountainhead may provide clients with a broad range of comprehensive financial planning services. Our financial planning is tailored to the individual needs of the client, and may include retirement planning, education planning, budgeting, cash flow and business planning, review of insurance, or recommendations for portfolio customization. We occasionally provide financial planning services on a stand-alone basis. In performing planning services, we typically obtain information from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) concerning financial data, goals, and resources. While we ask questions about the information and make a point of understanding the client’s situation, we do not independently verify the accuracy of the data provided to us. We often recommend that planning clients engage us for additional related services, such as implementation of financial plans, purchase of insurance (if applicable), and ongoing management of client assets (see Investment Management, below). A conflict of interest exists when we recommend our own services, or the use of insurance agents associated with Fountainhead or our insurance- licensed affiliate. Clients are under no obligation to act on any of the financial planning recommendations we make or to engage us for additional services. Investment Management Services Clients may engage Fountainhead to manage all or a portion of their assets on a discretionary or non- discretionary basis. Most of our client relationships are discretionary and we believe this structure permits us to implement our investment models and strategies more efficiently.  Discretionary. Fountainhead manages separate accounts with full discretion to invest a client’s assets subject to the client’s objectives and needs, and also subject to any guidelines or special instructions identified in the Agreement. Our discretionary authority permits us to delegate discretion on all or a portion of a client’s assets to third party investment managers (“Sub- Advisors”) as further described below. Most client management is performed by our affiliated investment advisor, Fountainhead AM, LLC (“FAM”).  Non-Discretionary. Fountainhead may also provide advisory services to separately managed accounts of clients on a non-discretionary basis, including to the IRA and 401K accounts of individuals. With respect to our non-discretionary asset management services, we generally maintain ongoing responsibility to make recommendations, based upon the needs of the client, as to the specific securities the account may purchase or sell. The final decision on investment selection rests with the client in this arrangement and the client always maintains asset control. Non-discretionary investment management services can negatively impact client accounts if Fountainhead is unable to contact clients during sudden negative market conditions. We may also render 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. In doing so, we recommend the allocation of client assets among the investment options available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. Depending on client status as a discretionary or non-discretionary account, we will either recommend (non-discretionary) or allocate (discretionary) client assets among Sub-Advisors (as described below), mutual funds, and exchange-traded funds (“ETFs”). As appropriate for the client, we may also incorporate other types of securities in our management strategy and may provide advice about any type of legacy investment held in clients’ portfolios. We ask clients to promptly notify us if there are changes in their financial situation or investment objectives, or if they wish to impose any reasonable restrictions upon our management services. Use of Sub-Advisors As mentioned above, and based on the stated investment objectives of the client, Fountainhead may authorize [for discretionary accounts] or recommend [for non-discretionary accounts] that clients authorize the active discretionary management of a portion of their assets by and/or among affiliated (FAM) and unaffiliated investment managers (collectively, “Sub-Advisors”) through our investment

platform. The terms and conditions under which the client engages Sub-Advisors are described in our Agreement with the client. In some cases, a given manager may enter into a direct relationship with the client, but this is unusual. Primary management of all Fountainhead client assets is handled through our relationship with FAM, our affiliated investment advisor. Fountainhead monitors and reviews the account performance and the client’s investment objectives, and maintains ongoing authority to hire and terminate Sub-Advisors or to allocate more or less of a client’s total assets to Sub-Advisors, including FAM. We receive an annual advisory fee based on a percentage of value of total assets managed. We pay a portion of our advisory fee to FAM. Other Sub-Advisor(s) assess separate fees for their services, in addition to what Fountainhead charges. All fees are described in the Agreement. We manage client assets through the use of model portfolios and investment strategies (“Strategies”) focused on specific objectives. We rebalance client portfolios regularly in light of market dynamics, to maintain a certain market exposure or take advantage of perceived opportunities. We do not intend to routinely select unaffiliated Sub-Advisors going forward, but will review information about and monitor the services of previously-selected Sub-Advisors who continue to manage our client assets. Where appropriate for a given client, our affiliate, FAM, will conduct due diligence and select Sub-Advisors on our behalf. When selecting or overseeing other Sub-Advisors FAM reviews information such as the Sub-Advisors’ Brochures and other material they supply. FAM evaluates the Sub-Advisors’ investment strategies, past performance and risk results to the extent available. Factors that we consider in recommending Sub-Advisors include the client’s stated investment objectives, the Sub- Advisor’s management style, performance, reputation, financial strength, reporting, pricing, and research. Clients will be charged additional fees for any Sub-Advisors used. The specific range of fees is described in the Agreement. In addition to Fountainhead’s and FAM’s Brochure, we also provide Brochures for any unaffiliated Sub-Advisors we use. Some Sub-Advisors may impose more restrictive account requirements or have different billing practices than Fountainhead. In such instances, Fountainhead may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Use of Affiliated Funds We anticipate that our Strategies, or those employed by FAM, will make some use of mutual funds advised or sub-advised by Exceed Advisory, LLC. See information concerning the conflicts this presents, as well as the related fees, in Items 5 and 10, below. We permit clients to direct us not to use any of these funds in their Accounts. Pension Consulting Fountainhead offers pension consulting services to employers. We will assist employers in developing defined benefit and defined contribution retirement plan solutions, which may include an evaluation of the qualified retirement plan’s fiduciary compliance program, recordkeeping and third-party administrative services, development of an investment policy statement, employee communication and education program, and retiree consulting services. Fountainhead may also provide investment management services to retirement plans, which includes the implementation and management of the plan assets. Important Information for Retirement Investors When we recommend that you rollover retirement assets or transfer existing retirement assets (such as a 401(k) or an IRA) to our management, we have a conflict of interest. This is because we will generally earn additional revenue when we manage more assets. In making the recommendation, however, we do so only after determining that the recommendation is in your best interest. Further, in making any recommendation to transfer or rollover retirement assets, we do so as a “fiduciary,” as that term is defined in ERISA or the Internal Revenue Code, or both. We also acknowledge we are a fiduciary under ERISA or the Internal Revenue Code with respect to our ongoing investment advisory recommendations and discretionary asset management services, as described in the advisory agreement we execute with you. To the extent we provide non-fiduciary services to you, those will be described in the advisory agreement. Tailored Advice and Client Restrictions We implement our advice or formulate planning recommendations based on individual client needs and it is important that clients notify us promptly of any change in their financial situation or investment objectives. We consult with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. 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 Fountainhead’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome for Fountainhead to administer. Sponsor / Manager of Wrap Program Fountainhead is not a sponsor or manager of a wrap fee program. Assets Under Management As of December 31, 2023, Fountainhead had approximately $693.3 million in discretionary assets under management and approximately $28.3 million in non-discretionary assets under management.