A. Virtue Capital Management, LLC Virtue Capital Management, LLC (“VCM”) is a limited liability company organized in the state of Tennessee. Virtue Financial Holdings, LLC (“VFH”), which owns 100% of Virtue Capital Management, LLC, is owned by Jeremy Rettich, Matthew Rettich, and James Webb. Jeremy Rettich and Matthew Rettich are the control persons of VFH. VCM has been offering investment advisory services since October 2013. B. Advisory Services Offered VCM is an asset management and financial planning firm offering a variety of investment management, financial planning, portfolio monitoring and third-party manager monitoring services to individuals, high-net-worth individuals, trusts, estates, charitable organizations, other investment advisers and the clients of such independent investment advisers. B.1. Investment Advisory and Portfolio Management Services VCM generally provides continuous and regular supervisory or management services. VCM gives continuous advice to its clients through its investment adviser representatives based on the individual needs of each client. VCM manages client accounts on a discretionary basis. VCM has discretionary authority regarding the securities to be bought or sold, the amount of securities to be bought or sold as well as the authority to hire and terminate third-party money managers. Account supervision is generally guided by the stated objectives of the client (e.g., capital appreciation, growth, income, or growth and income). Consideration is also generally given to the allocation of assets among securities-based investment strategies and managers and recommendations and selections are generally tailored to the client’s overall investment objectives and risk profiles. VCM’s investment committee also seeks to perform due diligence on third-party money managers and investment solutions prior to these being offered through the VCM platform and then strives to perform ongoing due diligence as to such managers and solutions. B.2. Selection of Other Advisers VCM may utilize or recommend sub-advisers or third-party money managers (“TPMMs”) to clients. VCM will generally be compensated via a fee share with the TPMMs to which it directs those clients. The fees shared will not exceed any limit imposed by any regulatory agency. Before recommending TPMMs to clients, VCM performs due diligence and research on such TPMMs. B.3. Consulting and Financial Planning Services Consulting and financial planning services may include, but are not limited to: investment planning, life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. The services and fees for such services are negotiated in advance and documented in an exhibit to the Financial Planning Agreement. VCM does not, however, provide tax or legal advice. In offering financial planning, a conflict exists between the interests of the investment adviser and the interests of the client since the investment adviser will benefit from the fees earned from managing the client’s assets in the event the client chooses to invest through the VCM platform. However, the client is under no obligation to act upon the investment adviser's recommendation, and, if the client elects to act on any of the recommendations, the client is under no obligation to affect the transaction through the investment adviser. This statement is required by California Code of Regulations, 10 CCR Section 260.235.2. Clients will usually receive a written or oral report (depending on the client’s preference) providing a basic financial plan designed to help achieve the client’s stated financial goals and objectives. Based on the client’s needs, financial planning services may include (but are not limited to) the following: ▪ Preparation of a recommended asset allocation that serves to diversify the client's portfolio among different categories of investments, such as domestic and international

small, medium, and large capitalization securities; corporate and government fixed income (short-, intermediate-, and long-term maturities); emerging market securities (i.e., foreign issuers); real estate investment trusts; and such other alternative asset categories including those offered through exchange traded funds that are suitable in light of the client's investment goals, objectives, and risk tolerance. ▪ Preparation of a retirement plan that serves to identify whether the client is saving enough and investing in a way that meets retirement objectives in light of the client's financial circumstances and risk tolerance. ▪ Preparation of cash flow projections to ensure that the client can meet daily living expenses and obligations. ▪ Insurance planning to meet the needs of the client, taking into account family, business, and other financial objectives of the client. ▪ General family office and business consulting:
• Retirement objectives
• Philanthropy
• Estate planning
• Wealth transition
• Business succession and related issues
• Recommendation of third-party managers for use by the client VCM usually gathers client information through, among other things, in-depth personal interviews and questionnaires. Information gathered includes a client's current financial status, investment objectives, future goals, and attitudes toward risk. Related documents supplied by the client are carefully reviewed, and a report may be prepared, subject to mutual agreement with the client and VCM, covering one or more of the above-mentioned topics as directed by the client. B.4. Retirement Answers 101 Financial Education Course We may offer this course to provide pre-retirees and retirees with a better understanding of the many financial planning areas that should often be considered as they enter into or maintain the lifestyle to which they have become accustomed during their retirement years. The materials covered in this course will revolve around addressing some of the greatest retirement fears including changes to investing as you near or enter retirement, social security election strategies, generating income, investment advice “suitability standard versus fiduciary responsibility,” and passive/strategic investing vs. active/tactical investing among many other topics. The information covered is general in nature and not intended to give specific investment advice to attendees. B.5. ERISA & Qualified Plan Services VCM offers to ERISA and other Qualified Plans consulting services that involve one or more of the following services, either onsite or through an electronic medium, as requested by the Plan: ▪ Enrollment meetings to Plan participants ▪ Education as to the Plan’s options and features ▪ Education for employees on financial topics such as compound interest, debt, benefits of financial planning as examples ▪ Discuss with HR payroll and related matters pertaining to Plan services and enrollment issues that may arise ▪ Individual discussions with employees regarding Plan features and operations ▪ Discuss investment changes with the Plan’s trustees that the 3(38) Plan fiduciary makes from time to time ▪ Periodically benchmark the plan as to costs and benefits to other plan providers to assess the Plan's competitiveness for industry, size, and features C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will usually be managed on the basis of the client’s financial situation and investment objectives. The client is required to notify the firm in writing of any reasonable instructions to be imposed on the management of the portfolio. D. Wrap Fee Programs VCM does not participate in wrap fee programs, where brokerage commissions and transaction costs are included in the asset-based fee charged to the client. E. Client Assets Under Management As of December 31, 2023, VCM managed approximately $787,466,708 in discretionary assets and $0 in non-discretionary assets.