Phillips Ray Capital Management, Inc. is an investment adviser with its principal place of business located in Fort Worth, Texas. Phillips Ray Capital Management, Inc. began conducting business in 2002. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).  Brian Michael Phillips, President, Chief Compliance Officer, Treasurer & Director Phillips Ray Capital Management offers the following advisory services to our clients: PORTFOLIO MANAGEMENT SERVICES Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Our investment recommendations are not limited to any specific product or service offered by a broker- dealer or insurance company. Portfolios most typically will consist of individual equities (including exchange-listed securities, securities traded over the counter or foreign issuers), bonds (including warrants, corporate debt securities (other than commercial paper), commercial paper, certificates of deposit, municipal securities and United States governmental securities) and no load or load-waived mutual funds. However, we may provide advice with respect to any of the following securities, which may also be included in a client’s portfolio, as appropriate: variable life insurance, variable annuities, options contracts on securities, and interests in partnerships investing in real estate or oil and gas interests. We will allocate the client's assets among various investments taking into consideration the overall management style selected by the client. Mutual funds are selected based on any or all of the following criteria: the fund's performance history; the industry sector in which the fund invests; the track record of the fund's manager; the fund's investment objectives; the fund's management style

and philosophy; and the fund's management fee structure. Portfolio weighing between funds or other securities, as well as market sectors, will be determined by each client's individual needs and circumstances. Clients will have the opportunity to place reasonable restrictions on the types of investments which will be made on the client's behalf. Clients will retain individual ownership of all securities. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. PORTFOLIO CONSULTING SERVICES For clients who do not use our Portfolio Management Services, we may provide individualized consulting services and review various investment alternatives for the client to determine which of these investment alternatives or a mix of various investments is most appropriate based on the client's individual financial circumstances, investment objectives, risk tolerances and income requirements among other factors. Under this service, we will make investment recommendations to the client as market factors and the client's needs dictate. This service is provided by Phillips Ray Capital Management on a consulting basis only. Once the investment recommendations are made, it is up to the client to implement the recommendations if he/she decides to do so. We will not accept any client’s username and password or other access or authority to access any client’s account to implement recommendations or otherwise. If requested, client investments may also be reviewed or monitored quarterly or on an as needed basis. In addition, if requested, we will meet with the client at least annually to review performance, allocation of assets, tax liability issues, update the client’s profile to reflect any changes in client circumstances, and review and effect any change of beneficiaries. CONSULTING SERVICES Clients can also receive investment advice on a more focused basis. This may include advice on an isolated area(s) of concern such as estate planning, retirement planning, or any other specific topic. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. Consulting recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a generic nature. AMOUNT OF MANAGED ASSETS As of 12/31/2023, we were actively managing $75,140,789 of clients' assets on a discretionary basis and $15,531,040 of clients’ assets on a non-discretionary basis.