A. Advisory Firm Description and Principal Owner Schaffer & Company Asset Management, Inc. (hereinafter “SCHAFFER” or the “firm”) is a Registered Investment Adviser with the Securities and Exchange Commission. Individuals associated with the firm provide SCHAFFER'S advisory services. These individuals are appropriately registered, qualified or authorized to provide advisory services on the firm's behalf and are known as Investment Adviser Representatives (IAR'S). Schaffer & Company Asset Management, Inc. was established in year 2005 to present. Gregory Lee Schaffer is an IAR's for the firm who is also the CEO, CIO, President and Director. The Gregory Lee Schaffer Living Trust dated 12/07/1999 is 100% shareholder of Schaffer & Company Asset Management, Inc. B. Types of Advisory Services Schaffer provides fully discretionary and non-discretionary portfolio management on a continuous basis. The investment advice provided by SCHAFFER is variable depending upon the desires, objectives, and other preferences of the client. Such advice may include the origination of investment ideas, investment buy/sell recommendations, and portfolio management, including the potential selection of securities for the account of the client on the basis of the client's needs and objectives. SCHAFFER offers comprehensive financial planning and general consultation services on an hourly basis at $270 per hour or on a fixed fee basis. The firm gives the client the flexibility to engage its services on either a one-time basis or ongoing basis. An IAR of the firm first conducts an initial consultation during which pertinent information about the client's current financial status, future goals, and attitude towards risk is collected. Once such information has been reviewed and analyzed, a written financial plan - designed to achieve the Clients' stated financial goals and objectives - will be produced and presented to the Client. In general, the financial plan will address the following areas: PERSONAL: Family records, budgeting, personal liability, estate information, and financial goals. TAX & CASH FLOW: Income tax and spending analysis and planning for past, current and future years. SCHAFFER will illustrate the impact of various investments on a client's current income tax and future tax liability. DEATH & DISABILITY: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis. RETIREMENT: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals. Form ADV: Part 2A Page 6 INVESTMENTS: Analysis of investment alternatives and their effect on a client's portfolio. Financial planning fees will be calculated based upon the extent and complexity of the individual client's personal circumstances. Fees for financial planning services will typically range from $600 to $1,500. All fees are agreed upon prior to entering into the financial planning agreement with the client. Financial

planning fees are due and payable upon completion of the contracted services. In limited circumstances, SCHAFFER may require a minimum fee. Financial plans are based on the client's financial situation at the time the plan is presented and are based on financial information disclosed by the client to SCHAFFER. Clients are advised that certain assumptions may be made with respect to interest and inflation rates and use of past trends and performance of the market and economy. Past performance is in no way an indication of future performance. SCHAFFER cannot offer any guarantees or promises that the client's financial goals and objectives will be met. Further, the client must continue to review any plan and update the plan based upon changes in the client's financial situation, goals, or objectives or changes in the economy. As the client's financial situation, goals, objectives, or needs change, client must notify SCHAFFER promptly. Should a client choose to implement the recommendations contained in the financial plan, SCHAFFER suggests the client work closely with his/her IAR, attorney, accountant, insurance agent, and/or stockbroker. Implementation of the financial plan is entirely at the client's discretion. In addition to the aforementioned services, SCHAFFER provides advice on non-securities matters. Generally, this in connection with the rendering of estate planning, tax planning, life changes, insurances, and/or annuity advice. The financial planning agreement may not be modified or amended except in writing and signed by both the SCHAFFER and the Client. SCHAFFER and the Client may terminate the agreement within five days of the date of acceptance with no penalty to the Client. After the five-day period, either party may terminate the agreement, at any time, effective upon the receipt of written notice. SCHAFFER will return to the Client any unused portion of the prepaid financial planning fees. C. Explanation of Tailoring Advisory Services Through personal discussions, the IAR will gather information from the Client including current investments (if any), and current financial condition, and obligations. The IAR will then recommend various types of investments to construct a portfolio suited to meet the Client's identified goals, financial needs and investment objectives in light of current economic and market conditions. A portfolio may include Exchange Traded Funds (ETF's) Mutual Fund shares, Variable Annuities, Individual stocks, Stock Options, Warrants, Bonds, CD's, Treasuries or any other investment product deemed suitable for client. D. Wrap Fee Programs SCHAFFER do not participate in wrap fee programs. Form ADV: Part 2A Page 7 E. Discretionary and Non-Discretionary Assets SCHAFFER manages client assets discretionary. The amount of client assets SCHAFFER manages on a discretionary basis is $62,822,948.71 as of December 31, 2023. SCHAFFER does not currently manage non-discretionary assets.