Corporate History InTrack Investment Management, Inc., previously Sopher Investment Management, has been in business providing advisory services since 1992. In 2016, Peltzer Capital Management joined InTrack Investment Management. The advisory firm has offices in South Burlington and Norwich, Vermont. The company’s Managing Partner and principal owner is Myron R. Sopher. Partners and owners in the firm include Myron R. Sopher, Brett C. Peltzer, CFA and MBA, Matthew D. Johnson, CFA. Brandon D. Tieso is an employee of the firm. Jan E. Peltzer serves as a consultant to the firm. Advisory Services Investment Management Services InTrack Investment Management (InTrack) clients and their families know our advisers are there to help them navigate change and stay on course to achieve their long-term financial goals by managing their investments. InTrack’s advisers integrate their understanding of a client’s individual circumstances and values with their expertise in finance, global economics, entrepreneurial ventures, impact investing, and socially responsible investing. Using the information collected, the adviser determines asset allocation, then constructs and manages the client’s portfolio based on the stated objective. While InTrack’s goal is to help clients manage their assets and financial lives, plus assist them in building and sustaining wealth, our advisers’ greatest pleasure is being an ever-present, trusted resource. InTrack’s advisers use their expertise to manage complex trust situations, provide solutions to concentrated investment positions, oversee clients’ retirement funds and help clients balance risk with other non-retirement accounts. Advisers assist clients with planned goals (saving for college, medical expenses) or unplanned events (death of a loved one and the transition of assets from one generation to the next). If a client requests that their adviser examine retirement planning and other investments related to retirement, the adviser may provide suggestions. Advisers educate clients so they understand their investments and the factors that affect their investments. InTrack’s investment advisory services are fee- based. Our investment strategies utilize publicly traded equities, fixed income and cash securities as described below.
• Stocks.
• Bonds including municipal, treasury, corporate, and foreign bonds that are investment grade. InTrack cannot control bond holdings in mutual funds and informs clients of this fact. Certain mutual funds may include lower than investment grade fixed income bonds.
• Exchange traded funds (ETFs)
• Mutual funds.
• Cash, cash equivalents, and certificates of deposit.
• Structured notes, private placements The majority of clients that work with InTrack advisers do so on a discretionary basis. If a client engages InTrack on a non-discretionary investment advisory basis, the client must accept that InTrack Investment Management cannot affect any account transactions without obtaining prior verbal consent from the client. This applies even in the event of a market correction. Without consent from the client, an adviser does not have the authority to execute trades. Financial Planning Services InTrack Investment Management offers customized financial planning services. The client can elect a one-time financial plan or a service that includes annual updates to the original plan. The financial planning service reviews personal and financial information using a fact gathering worksheet and investor profile questionnaire, interview process, current financial statements, income taxes, and estate planning documents. InTrack utilizes eMoney software in the preparation of the financial plan. eMoney software allows the client to view a consolidated asset allocation of their financial assets which can include assets InTrack does not manage. The plan may include an income, spending, and savings analysis while incorporating the client’s goals such as retirement and education savings. If requested, advisers analyze the client’s current investments and make recommendations based on the plan’s results. It is entirely the client’s decision to implement the plan, parts of the plan, or disregard the recommendations. Although InTrack may make recommendations, the firm is not responsible for the investment performance of any assets not managed by InTrack. If the client chooses to implement any of the plan’s recommendations, InTrack advises the client to consult closely with their attorney, accountant, insurance agent and financial adviser when implementing the plan. Money Coaching Services InTrack is offering Money Coaching Services to individuals and couples. This coaching program facilitates clients in exploring and solving common problems associated with managing personal finances. Working with the client, the adviser assists the client in discovering patterns, beliefs, and behaviors (many times subconscious behaviors), which impede thoughtful decisions related to money. The adviser and client then develop a strategy to modify the problematic patterns and enhance positive patterns. This allows the client to take control of day-to-day and long-term financial decisions. The client is responsible for following up and acting on the plan. InTrack is not responsible for financial decisions made and implemented by the client. Consulting and

Participant Directed Retirement Plan Consulting InTrack provides consulting services for some clients. Depending on the nature of the agreement, Advisers review individual securities and overall aggregate allocation then offer recommendations to align the portfolio with the client’s objectives, risk tolerance and current and future financial needs. It is the client’s responsibility to choose the recommendations that meet their objectives and execute those recommendations. Consulting services also include participant directed retirement plans. In these cases, advisers review and select mutual funds offered to the plan’s participants which are consistent with the plan’s objectives, provide general information on the benefits of investing in 401k plans, show historic return information on various asset classes, and offer general guidance on allocation of participant’s portfolios. Miscellaneous Retirement Plan Rollovers and Potential for Conflicts of Interest A client or prospective client leaving an employer typically has four options regarding an existing retirement plan and may engage in a combination of the following options.
• If permitted, leave the money in the former employer’s plan.
• Rollover the assets to the new employer’s plan, if one is available and rollovers are permitted.
• Rollover to an Individual Retirement Account (IRA).
• Cash out the account value which could, depending upon the client’s age, result in adverse tax consequences. If an adviser of InTrack recommends that a client rollover their retirement plan assets into an account to be managed by InTrack, such a recommendation creates a conflict of interest if InTrack will earn an advisory fee on the assets. To address this, InTrack requires all rollover clients to sign and understand our Rollover Disclosure document. No client is under any obligation to rollover retirement plan assets to an account managed by InTrack. If a client has any questions regarding the potential for a conflict of interest on a retirement plan rollover, please contact Myron R. Sopher, CCO. If a client requests information regarding retaining an attorney, accountant, insurance agent or any professional, advisers of InTrack Investment Management may recommend an individual or firm to assist the client. However, if a dispute arises between the client and the professional, InTrack is not held accountable for recommending the professional. The client shall seek recourse from the individual or firm they engaged to provide the professional service. InTrack is not responsible for the services rendered by the professional. Held-Away Management with Pontera InTrack Investment Management uses the Pontera platform made available by Pontera Solutions, Inc. (“Pontera”), a third party online platform, to assist with management of clients’ “held away” accounts, including 401(k)s, 403(b)s, annuities, and 529 education savings plans, and as an order management system for such accounts where InTrack implements tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. The specific fee schedule charged by InTrack for account management of held away assets is established in the client’s written agreement with InTrack. To facilitate use of the Pontera platform, the client securely logs into the Pontera site and entitles InTrack to manage the assets. Clients do not pay any additional fee to Pontera or to InTrack in connection with platform participation. InTrack is not affiliated with the Pontera platform in any way and receives no compensation from them for using their platform. Investment management fees are generally directly debited on a pro rata basis from client accounts. The exception for this is directly managed held-away accounts, such as 401(k)s on Pontera. As it is impossible to directly debit the fees from these accounts, those fees will be assigned to the client’s taxable accounts on a pro-rata basis. If the client does not have a taxable account, those fees will be billed directly to the client. Customizing Advisory Services InTrack Investment Management tailors each advisory relationship to the client’s needs by maintaining contact with each client through meetings, phone calls, and e-mails and determines if the individual’s circumstances or perspectives have changed which may result in a change to their investment objective. Upon a client’s request, and if the adviser believes the request can be honored, InTrack Investment Management is able to customize a client’s investments. Typically, a client might restrict the adviser from purchasing or holding certain securities, industries, or sectors. If the portfolio currently includes these holdings, the adviser will act upon the client’s decision to either sell or work to reduce the holding over time. These requests are documented. Each client is advised that it remains their responsibility to promptly notify InTrack Investment Management of any changes in their financial situation or investment objectives so the adviser can review, recommend, and incorporate the change into the client’s accounts. Wrap Fee Programs This item is not applicable. InTrack Investment Management does not participate in wrap fee programs. Client Assets Assets under management as of December 31, 2023. Discretionary: $263,241,460.13 Non-discretionary: $970,049.98