Capital Growth & Shelter, Inc. (the “Firm” or “we” or “us”) was established in 1984 and Kenneth Larry Hooker became the Firm’s sole owner in 1988. In 1993, the Firm registered as an investment adviser. 1 We provide investment advisory services to clients using model portfolios made up of Fidelity Advisors mutual funds on a non-discretionary basis.2 Capital Growth & Shelter, Inc. is wholly owned by Kenneth L Hooker. We offer non-discretionary asset management advisory services using an asset allocation program based on a client’s investment objectives, financial situation, time horizon, risk tolerance and other factors which are obtained at the initial meeting of the client. The asset allocation portfolio categories are: 1. Ultra Conservative – The goal of the portfolio is to provide a high degree of stability for investors with a lower degree of risk tolerance. The portfolio consists of mutual funds with diversified bond holdings, with a limited amount of equity and cash. This model is designed for investors who are risk-averse and with a goal of principal stability and income. 2. Conservative – The goal of the portfolio is to provide a diversified, portfolio of mutual funds that offer a lower level of risk by weighting the portfolio heavily with bonds and cash, while at the same time offering the potential for growth using a limited weighting of mutual funds that invest in equities. The portfolio seeks to achieve a higher rate of total return on investment through current income and capital appreciation. This model is designed for investors with a goal of principal stability and income but are willing to take on some risk. 3. Conservative+ - The goal of this portfolio is to offer the potential for higher long-term growth with a moderate amount of risk. This is designed for investors with a goal of principal stability and income but are willing to take on some risk. 4. Balanced – The goal of the portfolio is to attempt to provide both portfolio stability and the potential for capital appreciation. A balanced model between mutual fund equity and fixed income investments. The portfolio is slightly more weighted on the equity side to attempt to mitigate inflation risk over the long term. This is designed for investors with

a goal of growth but are willing to take on a moderate amount of risk. 5. Growth – The goal of the portfolio is to provide capital appreciation with less emphasis on income and portfolio stability. The portfolio invests in equity mutual funds with higher degree of risk which it attempts to offset using fixed income mutual funds and cash. This portfolio is best suited for investors who are willing to take on more risk to achieve their financial goals. 6. Growth+- The goal of the portfolio is to provide a higher degree of possible capital appreciation. The portfolio’s emphasis is on potential growth and consequently holds a higher weighting of equity mutual funds. The portfolio carries a higher degree of risk than other portfolios while still 1 Registration does not imply a certain level of skill or training. 2 Capital Growth & Shelter, Inc and Fidelity Advisors are not affiliated. attempting to maintain a degree of stability using fixed income mutual funds and cash. This portfolio is best suited for investors who are focused on growth of the portfolio and willing to assume a higher degree of risk. 7. High Growth – The goal of the portfolio is to provide a higher degree of capital appreciation. The fund assumes more risk the other portfolios the Firm offers. This model is heavily weighted in equity mutual funds with its primary goal being capital appreciation. This portfolio is best suited for investors who are willing to take on more risk to hopefully achieve more long-term growth. Clients can request us to create a custom portfolio made up of Fidelity Advisors mutual funds for them exclusively. We monitor and rebalance the client’s account quarterly according to the client’s model portfolio selection. Clients can change their selected portfolio at their discretion by discussing their situation and desire with the Firm. The Firm’s advisory services are limited to certain mutual funds Fidelity Advisors makes available for this asset allocation program, therefore clients may not impose restrictions on investing in certain securities or types of securities. If you choose to engage our services, you will enter into a written Asset Management Agreement and be charged an advisory fee for our services. As of December 31, 2023, the Firm had $0 of regulatory assets under management managed on a discretionary basis and $33,259,122 of regulatory assets under management managed on a non- discretionary basis.