Titleist Capital, LLC (referred hereinafter to as “TC” or the “firm”) was incorporated in the State of Texas in 2003 and is registered with the SEC as a Registered Investment Advisor (“RIA”). TC is also registered with the SEC as a Broker-Dealer (“BD”). Fields and O’Banion Investments, LLC, established in 2003, is the General Partner of TC’s RIA and BD. Mr. Byron L. Fields and Mr. Joe-Ben O’Banion are Managing Partners of the General Partner and TC. As of 03/31/2023, all assets being serviced by TC including both RIA and BD total $0. At the present time, the investment advisory assets under management are $0. The brokerage assets being serviced total $161,861,407. This amount is comprised of securities such as mutual funds, annuities, and alternative investments. A. Advisory Services Offered Investment Management Services TC sponsors an investment advisory program wrap fee program (“Program”), discretionary and non- discretionary, whereby our investment adviser representatives (“IAR”) will manage your assets within an advisory account for a single fee that includes portfolio management services, reporting and transaction costs. In a discretionary account, the customer gives the IAR the authorization to make purchases and sales in the account without first obtaining the customer’s permission. Under this program, we offer investment advice designed to assist you with professional management of your investments for a convenient single wrap fee. If you participate in the Program, we charge you a specified fee which covers our advisory services and the fees for executing transactions within your account. You may also choose to participate in our wrap fee program without granting discretion. Non-discretion requires that you provide instructions to the IAR regarding all activity in the account(s). You can change discretionary authorization at any time by doing so in writing and providing it to TC. Currently, there is one version of the Program. The Program is a “bundled” program, which means all transaction charges, advisory fees, execution services, and certain administrative fees are included in the fee charged to you. In the program, your TC IAR creates and manages the asset allocation model for you. More so, your TC IAR will furnish you with investment advice and recommend a portfolio of securities mentioned above that we consider appropriate to meet your specific investment goals and objectives. Prior to joining the Program, if you choose to have a discretionary account you will execute a Limited Trading Authorization Form with TC setting forth the terms and conditions of our management of your investments within the Program. TC will never have full trading authorization for your account. For both discretionary and non-discretionary accounts, a TC Account Profile Form will be completed and signed by both you and your IAR describing your financial needs, investment objectives, time horizon, and risk tolerance, as well as any other factors that are relevant to your specific financial situation and any other supporting documentation required for the Program. The gathering of this data (and other information obtained during the initial phase of our engagement, when applicable) enables us to design a tailored portfolio for you that will encompass your investment objectives, risk tolerance, and investment time horizon. Clients have the right to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio, and should promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. TC will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. TC will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. Fees and Compensation The fees and charges are applicable to new accounts opened on or after the new pricing effective date, June 29, 2017. Accounts opened prior to this date will reflect pricing that was previously in effect. Clients may consult with their IAR about their current program selection and determine if a change in program or fees may be necessary. You will be charged a maximum advisory fee of up to 2% for the management of your Program account. This advisory fee covers services which include portfolio construction, asset allocation, the ongoing review, at least annually, of your Program account, and certain brokerage-related services. The trading cost component of the advisory fee is estimated to range from $100 to $500 per account per year. Clients utilizing TC model strategies and/or third-party money managers (“PMM”) will be charged additional fees; please refer to our ADV Part 2A Brochure for information on model strategy and PMM services offered through TC. TC may utilize leverage in the management of its clients’ accounts and calculates its fees on the gross value of the portfolio. Although we strive to place our clients’ interests first, this practice creates an economic incentive for a firm to utilize leverage in order to increase its fee revenue. Quarterly fees billed in arrears in each following calendar quarter based on the value of assets under management at the end of the previous quarter and is payable within 30 days after the beginning of each following calendar quarter. Fees will not be prorated for contributions or withdrawals to a client’s portfolio for the quarter in which the change occurs. Should the advisory agreement be terminated, the client will be charged a prorated fee in accordance with the number of days that have elapsed from the beginning of the quarter in which the agreement was terminated through the date of termination. The cost of investment advisory services provided through the Program may be more or less than the cost of purchasing similar services separately. For example, if you expect to trade frequently, the Program could be a cost-effective approach. Conversely, if you and/or your IAR expect a lower level of trading activity, an unbundled pricing structure could be more appropriate. You should consider the value of services provided under a wrap fee program, as the wrap-fee could exceed the aggregate cost of services if provided separately. Your TC IAR will receive compensation as a result of your participation in the Program. The amount of the compensation may be more or less, than your TC IAR would receive if you participated in other advisory programs co-sponsored by TC or if you paid separately for investment advice, brokerage, and other services. You may group multiple Program accounts in order to obtain lower advisory fees based upon the total amount of assets under management. For illustrative purposes, “house-holding” shall mean aggregating eligible Program accounts in order to qualify for more favorable advisory fees. Eligible Program accounts include those registered in the name of the following members of the same family: spouse, child, child’s spouse, grandchild, grandchild’s spouse, brother, brother-in- law, sister, or sister- in-law. Program accounts that are not eligible for house-holding include, but are not limited to corporate accounts, Keoghs, 401(k)s, 403(b)s, investment clubs, estate accounts, and partnerships. We are not responsible for identifying accounts for house-holding and will household accounts only upon your specific written request. We may household additional Program accounts solely at our discretion. The assets of house-held accounts are not co-mingled and retain ownership rights and responsibilities. These fees include charges for all transaction costs such as commissions on purchase and sales of stocks, bonds, exchange-traded funds and options, and mutual fund transactions fees. Except as otherwise provided below, client will incur no charges other than the adviser’s fee pursuant to the above fee schedule in connection with the maintenance of and activity in client’s account. The wrap fee does not include annual account fees or other administrative fees, such as wire fees, charged by manager or brokerage firm; fees for securities transactions executed away from the custodian; certain odd-lot differentials, transfer taxes, transaction fees mandated by the Securities Act of 1934, postage and handling fees, and charges imposed by law with regard to transactions in the client’s account; and advisory fees, expenses or sales charges (loads) of mutual funds (including money market funds), closed-end investment companies or other managed investments, if any, held in client’s account. The wrap fee also does not cover certain costs associated with securities transactions in the over-the-counter market, such as fixed income securities where manager must approach a dealer or market maker to purchase or sell a security. Such costs include the dealer’s mark-up, mark-down or spread and odd-lot differentials or transfer taxes imposed by law. B. Disclosure of Cost Difference if Services Purchased Separately Depending on a number of factors, such as the number,

size and nature of the securities transactions in an advisory account, the overall fees and charges borne by the client over time could be more or less than what these fees and charges would be if the same services were provided on a separate basis. Bundled fees generally provide an economic incentive for the advisory firm to select investments and strategies that minimize trading costs. Frequent trading in an account where transaction fees are included as part of the overall advisory fee to the client drive trading costs higher and reduce the overall fee revenue to the advisor. As a result, higher trading costs in a bundled fee account have a negative impact on the advisory firm’s profitability. C. Additional Client Fees and Terms of Payment Client Payment of Fees Investment management fees will generally be billed and payable quarterly in arrears unless otherwise agreed to by the firm and client in writing. Quarterly fees billed in arrears at the beginning of each calendar quarter based on the value of assets under management at the end of the previous quarter and is payable within 30 days after the beginning of each calendar quarter. Should the advisory agreement be terminated, the client will be charged a prorated fee in accordance with the number of days that have elapsed from the end of the last billed quarter through the date of termination. TC requires clients to authorize the direct debit of fees from their accounts. Exceptions may be granted subject to the firm’s consent for clients to be billed directly for our fees. For directly debited fees, the custodian’s periodic statements will show each fee deduction from the account. Clients may withdraw this authorization for direct billing of these fees at any time by notifying us or their custodian in writing. TC will deduct advisory fees directly from the client’s account provided that (i) the client provides written authorization to the qualified custodian, and (ii) the qualified custodian sends the client a statement, at least quarterly, indicating all amounts disbursed from the account. The client is responsible for verifying the accuracy of the fee calculation, as the client’s custodian will not verify the calculation. A client investment advisory agreement may be terminated by either party with a 30-day written notice to the other. Upon termination, any unearned, prepaid fees will be promptly refunded and any earned, unpaid fees will be immediately due and payable. Additional Fees All fees paid for investment advisory services are separate and distinct from the fees and expenses charged by exchange-traded funds, mutual funds, separate account managers, private placement, pooled investment vehicles, broker-dealers, and custodians retained by clients. Such fees and expenses are described in each exchange-traded fund and mutual fund’s prospectus, each separate account manager’s Form ADV and Brochure and Brochure Supplement or similar disclosure statement, each private placement or pooled investment vehicle’s confidential offering memoranda, and by any broker-dealer or custodian retained by the client. Clients are advised to read these materials carefully before investing. If a mutual fund also imposes sales charges, a client may pay an initial or deferred sales charge as further described in the mutual fund’s prospectus. A client using TC may be precluded from using certain mutual funds or separate account managers because they may not be offered by the client's custodian. D. Compensation for Recommending the Program The Program is a proprietary product offered exclusively through TC. As such, there are no conflicts of interest in that there are no commissions paid for selling the Program. E. External Compensation for the Sale of Securities to Clients The firm’s advisory professionals are compensated solely through a salary and bonus structure. The firm is not paid any sales, service or administrative fees for the sale of mutual funds or any other investment products with respect to managed advisory assets. F. Important Disclosure – Custodian Investment Programs Please be advised that certain of the firm’s investment advisor representatives are registered with a broker-dealer and/or the firm is a broker-dealer or affiliated with a broker-dealer. Under these arrangements, TC can access certain investment programs offered through the broker-dealer that offer certain compensation and fee structures that create conflicts of interest of which clients need to be aware. As such, the investment advisor representative and/or the firm may have an economic incentive to recommend the purchase of 12b-1 or revenue share class mutual funds offered through the broker-dealer platform rather than from the investment advisor platform. Ultimately, it is the client’s decision to open an account through the broker-dealer or investment advisor platform. Factors clients should consider are the size of the portfolio, number of portfolio securities and the expected number of transactions to be effected. Clients should discuss with their financial advisor the pros and cons of each platform. Limitation on Mutual Fund Universe for Custodian Investment Programs: Please note that as a matter of policy we prohibit the receipt of revenue share fees from any mutual funds utilized for our advisory clients’ portfolios. There are certain programs in which we participate where a client’s investment options may be limited in certain of these programs to those mutual funds and/or mutual fund share classes that pay 12b-1 fees and other revenue sharing fee payments, and the client should be aware that the firm is not selecting from among all mutual funds available in the marketplace when recommending mutual funds to the client. Conflict Between Revenue Share Class (12b-1) and Non-Revenue Share Class Mutual Funds: Revenue share class/12b-1 fees are deducted from the net asset value of the mutual fund and generally, all things being equal, cause the fund to earn lower rates of return than those mutual funds that do not pay revenue sharing fees. The client is under no obligation to utilize such programs or mutual funds. Although many factors will influence the type of fund to be used, the client should discuss with their investment adviser representative whether a share class from a comparable mutual fund with a more favorable return to investors is available that does not include the payment of any 12b-1 or revenue sharing fees given the client’s individual needs and priorities and anticipated transaction costs. In addition, the receipt of such fees can create conflicts of interest in instances (i) where our adviser representative is also licensed as a registered representative of a broker-dealer and receives a portion of 12b-1 and or revenue sharing fees as compensation – such compensation creates an incentive for the investment adviser representative to use programs which utilize funds that pay such additional compensation; and (ii) where the custodian receives the entirety of the 12b-1 and/or revenue sharing fees and takes the receipt of such fees into consideration in terms of benefits it may elect to provide to the firm, even though such benefits may or may not benefit some or all of the firm clients. Additional Disclosure Concerning Wrap Programs: To the extent that we either sponsor or recommend wrap fee programs, please be advised that certain wrap fee programs may (i) allow our investment adviser representatives to select mutual fund classes that either have no transaction fee costs associated with them but include embedded 12b-1 fees that lower the investor’s return (“sometimes referred to as “A-Shares,” depending on the mutual fund issuer), or (ii) allow the use of mutual fund classes that have transaction fees associated with them but do not carry embedded 12b-1 fees (sometimes referred to as “I-Shares,” depending on the mutual fund sponsor). Wrap fee programs offer investment services and related transaction services for one all-inclusive fee (except as may be described in the applicable wrap fee program brochure). The trading costs are typically absorbed by the firm and/or the investment representative. If a client’s account holds A-Shares within a wrap fee program, the firm and/or its investment adviser representative avoids paying the transaction fees charged by other mutual fund classes, which in effect decreases the firm’s costs and increases its revenues from the account. Effectively, the cost is transferred to the client from the firm in the form of a lower rate of return on the specific mutual fund. This creates an incentive for the firm or investment adviser representative to utilize such funds as opposed to those funds that may be equally appropriate for a client but do not carry the additional cost of 12b-1 fees. As a policy matter, the firm does not allow funds that impose 12b- 1 or revenue sharing fees on the client’s investment within its wrap fee programs. Clients should understand and discuss with their investment adviser representative the types of mutual fund share classes available in the wrap fee program and the basis for using one share class over another in accordance with their individual circumstances and priorities. Item 5: Account Requirements and Types of Clients