Firm Description Beta Capital Management, LLC (“Creand” or the “Adviser”) was founded in 2011 and offers investment advisory services to individuals, institutions, trusts, estates, corporations and other business entities. Creand’s investment advisory services provide clients with investment advice and recommendations that are recommended to be used to implement their financial plans. Effective September 27, 2021, the Adviser operates under the Creand Management and/or Creand Wealth Management brand name. The change is part of the international unification of Crèdit Andorrà Financial Group under the new Creand brand, enhancing synergies between financial centers and improving efficiency to meet the new challenges of the future. Investment advice is an integral part of financial planning and Creand advises clients regarding securities transactions, cash flow, college planning, and retirement planning. Investment advice is provided on either a discretionary or non- discretionary basis, with each client making the final decision on investment selection when being advised on a non- discretionary basis. When the Adviser is advising clients on a discretionary basis, Creand can make investment decisions surrounding asset allocation and place trades for clients (without prior consent) under a limited power of attorney authority. Principal Owners 100% of Creand is principally owned by Credit Andorra U.S.G.P. LLC. For more information related to the ownership or principal structure of the Adviser, please contact Creand or visit www.adviserinfo.sec.gov. Types of Advisory Services Creand provides investment advisory services primarily to high net-worth individuals. More specifically, Creand provides asset management, and advisory services as well as furnish investment advice through consultations on both a fixed fee and/or hourly basis. On a periodic basis, Creand furnishes advice to clients on matters not involving securities, such as financial planning matters, taxation issues, and trust services that may include estate planning. Tailored Relationships The goals and objectives for each client are documented by the Adviser and will vary by client. Investment policy statements can be created to reflect the stated goals and objectives of each client. Creand’s Investment Adviser Representatives (“IARs”) work with their clients to identify their investment goals and objectives, as well as risk tolerance, in order Beta Capital Management, LLC P a g e | 5 to create a portfolio allocation designed to complement the client’s financial situation and personal circumstances. The initial meeting to review clients’ investment portfolios may be conducted by telephone or in person and is free of charge. The initial meeting is considered an exploratory interview to determine the extent to which financial planning and investment management may be beneficial to each potential and current client. The IAR can periodically rebalance the client’s account to maintain the initially agreed upon strategic and tactical asset allocation. However, no changes are made to the agreed- upon asset allocation in non-discretionary accounts without prior client review and consent. Clients have ready access to their respective IAR. IARs are not required to be available for unscheduled or unannounced visits by clients. However, IARs are expected to periodically meet with clients and should generally be available to take client telephone calls on advisory-related matters. Each client has the opportunity to place reasonable restrictions on the type of investments to be held in their portfolio(s). Other professionals (e.g., lawyers, accountants, insurance agents, etc.) may be recommended to clients or engaged directly by the client on an as-needed basis. Any potential conflict of interest related to recommendations of other professionals will be disclosed to the client in the event they should occur. Creand’s Advisory Agreements are not assigned without client consent. Types of Agreements Creand offers a variety of customized advisory services, which are outlined and defined in each client’s investment advisory agreement. Advisory Service Agreement Most clients choose to have Creand manage their assets on an ongoing basis in order to obtain continued in-depth investment advice and planning. All aspects of the client’s financial affairs are reviewed, which may include those of their children. Realistic and measurable goals are set and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The scope of work and fee for an Investment Advisory Service Agreement

is provided to the client in writing prior to the start of the relationship. An Advisory Service Agreement includes: cash flow management; investment management (including performance reporting); education planning; retirement planning; estate planning; as well as the implementation of recommendations within each area. The annual Advisory Service Agreement fee is based on a percentage of the investable assets and clients have the option to choose from the following schedules most appropriate for them: Beta Capital Management, LLC P a g e | 6 Fee Schedule 1 INVESTMENT MANAGEMENT FEES OF CREAND Assets Under Mgmt Advisory Fee (does not include transaction fees and ticket charges) Between $1-$3 Million 1.55% Between $3-$10 Million 1.25% Between $10-$25 Million 0.95% Between $25 Million or greater 0.65% Orders executed through its affiliate broker-dealer, Beta Capital Securities, LLC (“Creand Securities”) will be assessed a $100.00 ticket charge per transaction. FUNDS TO BE INVESTED: US$ INVESTMENT MANAGEMENT FEE TO BE CHARGED: Beta Capital Management, LLC P a g e | 7 Fee Schedule 2 INVESTMENT MANAGEMENT FEES OF CREAND MANAGEMENT Fixed Advisory Fee of 0.375% plus Commissions & related transaction fees and ticket charges assessed by its affiliate broker-dealer, Creand Securities. Creand Securities Commissions Fee Minimum Ticket Charge CORPORATE BOND 1.00% $150.00 MUNICIPAL BOND 1.00% $150.00 OPTIONS 1.00% $100.00 EQUITY below $5 1.00% $100.00 EQUITY between $5 - $100 1.00% $100.00 EQUITY above $100 1.00% $100.00 TREASURY BILL less 1 year 0.30% $150.00 TREASURY NOTE more 1 year 0.60% $150.00 MUTUAL FUNDS EQUITY 1.50% $100.00 MUTUAL FUNDS FIXED INCOME 1.00% $100.00 STRUCTURES PRODUCTS 2.00% $150.00 FUTURES (HALF TURN) $15.00 $15.00 Beta Capital Management, LLC P a g e | 8 _____________________________________________________________________________________________________ Hourly Planning Creand provides hourly advisory and/or planning services for clients who need advice on a limited scope of work. The hourly rate for limited scope engagements varies, yet will not exceed $500 per hour. _____________________________________________________________________________________________________ Asset Management Client’s portfolio may consist of a variety of financial products, including, but not limited to: exchange-traded funds (“ETFs”), mutual funds, equities, options, and fixed income securities. The investment strategies utilized and portfolios constructed and managed depend on the individual client’s investment objectives and goals as provided to the IAR. Initial public offerings (“IPO’s”) are not available to clients of Creand. Please note that investment products are typically purchased or sold through a brokerage account. The brokerage firm typically charges a commission for investment products and Creand almost exclusively recommends clients to its affiliated FINRA broker-dealer member firm, Creand Securities. As a broker/dealer, the Firm offers a variety of financial products and/or services and may render advice as to the value and/or advisability of purchasing or selling securities, without receiving additional compensation, as such activities are solely incidental to the conduct of its business as a broker-dealer. The annual Asset Management Service Agreement fee is based on a percentage of the investable assets according to the following above schedules available to choose from. Client relationships can be established and exist where the fees are higher or lower than the fee schedules provided above. Please be advised that clients can choose to utilize a different broker-dealer, aside from Creand Securities as similar products and services can be purchased for a lower cost than offered by the Firm. As of December 31, 2023, Creand managed approximately $375,965,310 in assets on a discretionary basis and approximately $136,336,801 in assets on a non-discretionary basis. Termination of Agreement Although the Advisory Service Agreement is perpetual, the length of service can be terminated by the client at its discretion. Similarly, the client or the Adviser can terminate the Investment Advisory Service Agreement by written notice to the other party with a thirty day advance notice or as agreed upon otherwise between the client and the Adviser. If an agreement is terminated during a time period in which the client has already paid Creand its advisory fees in advance, then the Adviser will reimburse, on a pro-rata basis, the remaining advisory fees collected for any service not rendered. These fees will then be sent to the client’s address of record, unless otherwise directed by the client, within (30) days of termination of the agreement. Beta Capital Management, LLC P a g e | 9