General Information Trademark Capital Management Inc. (“TCM” or “we”) was formed in 1995, and provides institutional advisory services to other investment professionals, retirement plans, private funds and collective investment funds. We also provide personalized wealth management services including financial planning and portfolio management services. TCM also does business under the names “Trademark Capital Asset Management” and “Trademark Sports Management.” Joseph G. Ezernack, Jr. and Donald Beasley are the principal owners of TCM. Please see Brochure Supplements, Exhibit A, for more information on these principal owners and other individuals who formulate investment advice and have direct contact with clients, or have discretionary authority over client accounts. Our investment advisory services are provided to you through an appropriately licensed and qualified individual who is an investment adviser representative of TCM (referred to as your “Investment Adviser Representative” or “IAR” throughout this brochure). Your IAR may either be an employee of TCM or an independent contractor. IARs are free to negotiate the fees to be charged for the services provided within the parameters set by TCM, as disclosed in Item 5 – Fees and Compensation of this brochure. It is possible that different IARs may charge different fees for providing the same service to clients. The specific level of services you will receive and the fees you will be charged will be specified in your investment advisory agreement. As of December 31, 2023, we managed $209,395,907 on a discretionary basis, and no assets on a non- discretionary basis. INSTITUTIONAL ADVISORY SERVICES Sub-Advisory Services (Asset Management for Clients of other Investment Professionals) Other registered investment advisers and investment professionals (the “primary advisers”) may recommend or hire us to manage their clients' assets. In these arrangements, we will implement and manage an investment strategy in the client’s account; however, we do not serve as the primary adviser to the client. The primary adviser will retain direct contact with the client and will manage the client relationship. The primary adviser’s client will typically enter into an advisory contract directly with us or alternatively, depending on the contractual arrangement the client has with the primary adviser, we may contract directly with the primary adviser to provide the client investment advisory services. We will have exclusive investment discretion as to which securities shall be purchased or sold in the sub-advised client’s account in a manner consistent with the client’s selected product, investment objectives, policies and restrictions (if any) and the capabilities of the broker-dealer. In order to determine whether the strategy is suitable for a client, the primary adviser and the client are responsible for ascertaining the goals and objectives of the portfolio in question. In addition, we will obtain initial documentation of the client’s risk parameters and investment objectives. However, it is the responsibility of the primary adviser and/or the client to promptly notify us of any changes in financial condition of the client that would necessitate a change in the client’s investment objective. Clients may impose certain written restrictions on us in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Collective Investment Funds We also serve as the sub-adviser to various collective investment funds (the “Trademark Funds”) (each reflecting a different investment strategy), sponsored by Hand Benefits & Trust Company (“HB&T”), a state-chartered trust company regulated by the Texas Department of Banking. Collective funds represent a pooled group of accounts that are combined to create a larger, diversified portfolio, typically a fund of grouped assets contributed by pension, profit sharing, retirement, or other trusts that are exempt from federal income tax. These pooled funds are grouped into what is commonly referred to as a master trust account under the control of the fund custodian (here HB&T) which acts as the administrator. Retirement Plan Advisory Services We provide Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The particular services provided will be detailed in the consulting agreement. The appropriate Plan Fiduciary(ies) designated in the Plan documents (i.e.., the Plan sponsor or named fiduciary) will (i) make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and (iii) make the ultimate decision as to accepting any of the recommendations that we may provide. The Plan Fiduciaries are free to seek independent advice about the appropriateness of any recommended services for the Plan. Retirement Plan consulting services may be offered individually or as part of a comprehensive suite of services which can be used with any Plan provider, record keeper, or Plan administrator. The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan Fiduciaries may retain investment advisers for various types of services with respect to Plan assets. For certain services, we will be considered a fiduciary under ERISA. For example, we will act as a fiduciary when providing non-discretionary investment advice to the Plan Fiduciaries by recommending a suite of investments as choices among which Plan Participants may select. Also, to the extent that the Plan Fiduciaries retain us to act as an investment manager within the meaning of ERISA § 3(38), we will provide discretionary investment management services to the Plan. Stand Alone 3(38) Program We will implement a multi-step process to carry out the fiduciary responsibilities associated with our discretionary management of the Plan’s investments. We will assist the Plan Fiduciary with establishing an Investment Policy Statement (“IPS”) for suitable investment options under the Plan and will evaluate and designate the specific investments to be offered as Plan investment options to Plan Participants. Investment options will be monitored and changed as deemed appropriate in our discretion. We shall also prepare reports evaluating the performance of Plan’s investments and comparing the performance to the benchmarks set forth in the IPS or as otherwise determined in consultation with the Plan Fiduciary. We will also establish and maintain a fiduciary audit file. As a condition for participating in the Stand Alone 3(38) Program, the Plan Fiduciary must agree to offer the Trademark Capital Multifactor Fund or the Trademark Capital Multifactor Conservative Fund (the “Trademark Funds”), a series of collective investment funds held in trust by the HB&T and advised by us, as an investment option for Participants if the Trademark Funds are available on the investment platform. Once the Plan Fiduciary determines that the Trademark Funds are suitable for the Plan, in no event shall we provide any discretionary or non-discretionary investment advice regarding the prudence of maintaining or continuing investments in the Trademark Funds. Full Service 3(38) and 3(21) Programs In addition to the Stand Alone 3(38) Program, we offer a Full Service 3(38) Program. The Full Service 3(38) Program encompasses the Stand Alone 3(38) Program described above but is offered in conjunction with non-fiduciary services (described below), as selected by each client. We also offer a non-discretionary Full Service 3(21) Program, where in addition to providing the non- fiduciary services described below, we will assist the Plan Fiduciary establish an Investment Policy Statement (IPS) for suitable investment options under the Plan. We will provide Plan Fiduciaries with recommendations of investment options consistent with the IPS and ERISA section 404(c). Plan Fiduciaries retain responsibility for the final determination of investment options and for compliance with ERISA section 404(c). Upon request, we will meet with the Plan Fiduciary periodically to review variances with the IPS and to recommend changes to the IPS or to the investments, and assist with the implementation of any approved changes. We will prepare reports evaluating the performance of Plan’s investments and comparing the performance to benchmarks set forth in the IPS or as otherwise determined in consultation with the Plan Fiduciary. We shall also maintain written minutes of meetings held with the Plan Fiduciary and also establish and maintain a fiduciary audit file. As a condition for participating in the Full Service 3(38) and/or 3(21) Programs, the Plan Fiduciary must agree to offer the Trademark Funds, a series of age-based collective

investment funds held in trust by the Hand Benefits & Trust Company and advised by us as an investment option for Participants. Once the Plan Fiduciary determines that the Trademark Funds are suitable for the Plan, in no event shall we provide any discretionary or non-discretionary investment advice regarding the prudence of maintaining or continuing investments in the Trademark Funds. Non-Fiduciary Services At the request of Plan Fiduciaries that have chosen to utilize TCM’s Full Service 3(38) and/or 3(21) Programs, we will include the following non-fiduciary services:
• Plan Evaluation. If selected, we will provide the Plan Fiduciary with a comprehensive benchmarking report that measures a variety of the Plan’s current metrics against the metrics of other similar retirement plans. Plan metrics may include and are not limited to plan features, participation rates, deferral rates, investment funds, record-keeping fees, administrative costs and fund expenses.
• Participant Education. If selected, we will deliver financial education across all levels of employees of the Plan Sponsor, regardless of their participation in the Plan, to enable them to confidently accumulate and manage their savings toward their retirement. Participant education services shall be consistent with and within the scope of Interpretive Bulletin 96-1. As such, we will not provide fiduciary investment advice (as defined in ERISA) to the participants and will not provide investment advice concerning any investment option or combination of investment options for a particular participant or beneficiary under the Plan. We will also provide the following ala carte non-fiduciary services for separate and additional compensation:
• Vendor Selection. If selected, we will provide assistance to the Plan Fiduciary in regard to the selection of a vendor on behalf of the Plan. The goal of this service is to assist and empower the Plan Fiduciary to make an informed and knowledgeable vendor selection decision.
• Extra Meetings and Reports. If selected, we will attend additional fiduciary and employee meetings and provide additional reports in connection with providing fiduciary services. WEALTH MANAGEMENT SERVICES Financial Planning and Ongoing Financial Consulting Services We also offer financial planning and ongoing financial consulting services on a fee basis to help you achieve your stated financial goals and objectives. This services may be provided as a stand-alone basis or may be coupled with ongoing portfolio management. Personal financial planning and consulting services may include, among other things, advice that addresses one or more areas of a client's financial situation, such as estate planning, risk management, retirement planning, budgeting and cash flow controls, retirement planning, education funding, and investment portfolio design. In some circumstances, planning advice may require the services of a specialist such as an accounting, insurance, trust provider, attorney, or tax accountant. We may recommend third-party service providers, but you are under no obligation to use any service provider we recommend. Fees for specialists will be negotiated between you and the service provider directly. You are under no obligation to engage our firm for additional services or implement any financial planning recommendations we make. Portfolio Management We will manage your assets on a discretionary basis. As a discretionary adviser, we will have the authority to supervise and direct your investment portfolio without prior consultation with you. Notwithstanding the foregoing, you may impose certain written restrictions on us in the management of your investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. You should note, however, that restrictions imposed by you may adversely affect the composition and performance of your investment portfolio. You should also note that your investment portfolio is treated individually by giving consideration to each purchase or sale for your account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ and you should not expect that the composition or performance of your investment portfolios would necessarily be consistent with those of our similar clients. We primarily allocate your investment management assets among mutual funds, ETFs, equities and individual debt in accordance with your investment objectives. We also provide advice about any type of investment held in your portfolios. We tailor our advisory services to your individual needs. We consult with you initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact your investment needs. Based on your risk tolerance, investment objectives and financial qualifications, we may also recommend that a portion of your assets be invested in private investment funds. You will be provided with private placement memorandums and other offering and subscription documentation that detail the nature, risks and associated fees of each private fund. It is important that you read and review these documents with your legal and tax advisors, before investing, to fully understand the types of investments, risks and conflicts pertaining to the funds. You are advised to promptly notify us if there are changes in your financial situation or investment objectives or if you wish to impose any reasonable restrictions upon our management services. You may impose reasonable restrictions or mandates on the management of your account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in our sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to our management efforts. Trademark Capital Risk Managed Income Fund, LP We serve as the General Partner and investment manager of the Trademark Capital Risk Managed Income Fund, LP and the Trademark Partners Fund, LP (together, the “Funds”). The Funds are pooled investment vehicles that are not registered under the Investment Company Act of 1940, as amended. Additionally, the Funds are not registered with the Securities and Exchange Commission. Investors must be “accredited investors,” within the meaning under Regulation D of the Securities Act of 1933; and in some instances, must also be “qualified clients” within the meaning of Rule 205-3 of the Investment Advisers Act of 1940. From time to time, as appropriate and in accordance with the established investment plan and risk tolerance of certain of our clients, we recommend investments in the Funds. Clients investing in the Funds are assessed a fee that is a percentage of assets under management in the Funds. In addition, depending on the specific fund, we also receive a performance allocation from investors’ accounts as described in the fund’s offering documents. A performance-based fee can create an incentive to make risker, more speculative investments than would be the case under a solely asset-based fee arrangement. Please see Item 6 - Performance-Based Fees and Side-By-Side Management below for more information. Our investors are provided with a private placement memorandum (“PPM”) and other offering and subscription documentation that detail the nature, risks and associated fees of the Funds. It is important that you read these documents before investing to fully understand the types of investments, risks and conflicts pertaining to the Funds. Please see Item 10 - Other Financial Industry Activities and Affiliations for more information about the Funds. Retirement Plan/Account Rollovers We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. If we recommend that you transfer your IRA or roll over your retirement assets into an account to be managed by us, such a recommendation creates a conflict of interest if we will earn a new (or increase our current) advisory fee because of the transfer or rollover. Investing in an IRA with us is usually more expensive than an employer- sponsored retirement plan. You are under no obligation to transfer your IRA or roll over plan assets to an IRA managed by us or to engage us to monitor and/or manage a plan account while maintained at your employer.