General Information Strathmore Capital Advisors, Inc. (“Strathmore Capital”) was formed in 2005 and provides portfolio management and retirement plan consulting services to its clients. John Charles Kernodle is the sole principal owner of Strathmore Capital. Please see Strathmore Capital’s Brochure Supplement for more information on Mr. Kernodle and other individuals who formulate investment advice and have direct contact with clients or have discretionary authority over client accounts. As of December 31, 2023, Strathmore Capital managed $379,270,872 on a discretionary basis and $11,707,855 on a non-discretionary basis. Services Provided At the outset of each client relationship, Strathmore Capital spends time with the client, asking questions, discussing the client’s investment experience and financial circumstances, and reviewing options for the client. Based on its reviews, Strathmore Capital generally develops with each client:
• a financial outline for the client based on the client’s financial circumstances and goals, and the client’s risk tolerance level (the “Financial Profile” or “Profile”); and
• the client’s investment objectives and guidelines (the “Investment Plan” or “Plan”). The Financial Profile is a reflection of the client’s current financial picture and a look to the future goals of the client. The Investment Plan broadly outlines the types of investments Strathmore Capital will make or recommend on behalf of the client to meet those goals. The Profile and the Plan are discussed regularly with each client but are not necessarily written documents. Financial Planning Advice For clients in need of such services, Strathmore Capital includes ongoing goals-based financial planning advice regarding many aspects of the client’s personal wealth with its Portfolio Management services. This advice is typically not offered as a standalone service or for a separate fee but is provided in conjunction with the management of the portfolio. Like all services provided by Strathmore Capital, planning advice is customized to meet the individual needs of each client and generally addresses one or more areas of a client's financial situation. Depending on a client’s particular situation, financial planning may include some or all of the following:
• Gathering factual information concerning the client's personal and financial situation;
• Assisting the client in establishing financial goals and objectives;
• Analyzing the client's present situation and anticipated future activities in light of the client's financial goals and objectives;
• Identifying problems foreseen in the accomplishment of these financial goals and objectives and offering alternative solutions to the problems;
• Making recommendations to help achieve retirement plan goals and objectives;
• Designing an investment portfolio to help meet the goals and objectives of the client;
• Providing estate planning;
• Assessing risk and reviewing basic health, life, and disability insurance needs; or
• Reviewing goals and objectives and measuring progress toward these goals. The client is under no obligation to act upon any of the financial planning recommendations made by Strathmore Capital and/or to engage the services of any recommended professional. Portfolio Management As described above, at the beginning of a client relationship, Strathmore Capital meets with the client, gathers information, and performs research and analysis as necessary to develop the client’s Investment Plan. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by Strathmore Capital based on updates to the client’s financial situation or other circumstances. To implement the client’s Investment Plan, Strathmore Capital will manage the client’s investment portfolio on a discretionary basis. As a discretionary investment adviser, Strathmore Capital will have the authority to supervise and direct the portfolio without prior consultation with the client. Notwithstanding the foregoing, clients may impose certain written restrictions on Strathmore Capital 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. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client’s investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client’s account. For these and other reasons, performance of separate client investment portfolios within the same investment objectives, goals and/or risk tolerance will differ, and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with that of similar clients of Strathmore Capital. Retirement Plan Advisory Services Strathmore Capital also provides advisory services to participant-directed qualified retirement plans (“Plan(s)”) through third-party administration services. These providers of online bundled services offer passive investment

vehicles and an opportunity for Plan sponsors to offer diversified portfolios to their participants along with daily account access, valuation, and investment education. The particular services provided will be detailed in the Plan’s respective agreement. The appropriate Plan Fiduciary(ies) designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i) make the decision to retain Strathmore Capital; (ii) agree to the scope of the services that Strathmore Capital will provide; and (iii) make the ultimate decision as to accepting any of the recommendations that Strathmore Capital may provide. Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring that prudent procedural steps are followed in making investment decisions. The Plan Fiduciaries are free to seek independent advice about the appropriateness of any recommendations for the Plan. The following Retirement Plan consulting services may be offered individually or as part of a comprehensive suite of services. Fiduciary Consulting Services
• Investment Selection Services: Strathmore Capital will provide Plan Fiduciaries with recommendations of investment options consistent with section 404(c) of the Employee Retirement Income Security Act of 1974 (“ERISA”). Plan Fiduciaries retain responsibility for the final determination of investment options and for compliance with ERISA section 404(c).
• Discretionary Investment Advice: Strathmore Capital uses a third-party platform to offer management services for certain held-away assets, such as defined contribution Plan Participant accounts, on a discretionary basis. Strathmore Capital does not have direct access to client login credentials to effect trades. Strathmore Capital is not affiliated with the platform in any way and receives no compensation from them for using their platform. A link will be provided to the client allowing them to connect an account to the platform. Once a client account is connected to the platform, Strathmore Capital will review the current account allocations. When deemed necessary, Strathmore Capital will rebalance the account considering factors such as, but not limited to, client investment goals, client risk tolerance, current economic, and market trends. Client accounts will be reviewed consistent with Item 13 – Review of Accounts below, and allocation changes will be made as Strathmore Capital deems necessary.
• Non-Discretionary Investment Advice: Strathmore Capital offers Plan Fiduciaries and Plan Participants general, non-discretionary investment advice regarding asset classes and investments.
• Investment Monitoring: Strathmore Capital will assist in monitoring the Plan’s investment options by reviewing periodic investment reports prepared by the third-party administration services referenced above. These reports document investment performance, consistency of fund management, and conformation to the guidelines set forth in the Investment Policy Statement. Strathmore Capital will also make recommendations to maintain or remove and replace investment options. The details of this aspect of service will be enumerated in the engagement agreement between the parties.
• Plan Investment Policy Statement/Investment Documentation Process: Strathmore Capital will assist the Plan Fiduciary with the drafting, design, implementation, maintenance, and review of an Investment Policy Statement or other investment documentation process. Non-Fiduciary Services
• Participant Education: Strathmore Capital will provide education services to Plan Participants about the benefits of saving for retirement, general investment principles, and the investment alternatives available under the Plan. Education presentations will not take into account the individual circumstances of each Plan Participant and individual recommendations will not be provided unless a Plan Participant separately engages Strathmore Capital for such services. Plan Participants are responsible for implementing transactions in their own accounts.
• Participant Enrollment: Strathmore Capital will assist with group enrollment meetings designed to increase retirement Plan participation among employees and investment and financial understanding by the employees. 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, Strathmore Capital will be considered a fiduciary under ERISA. For example, Strathmore Capital will act as an ERISA § 3(21) 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. Strathmore Capital does not provide discretionary investment management services to Plans as defined under ERISA § 3(38). With respect to any account for which Strathmore Capital meets the definition of a fiduciary under Department of Labor rules, Strathmore Capital acknowledges that both Strathmore Capital and its related persons are acting as fiduciaries. Additional disclosure may be found elsewhere in this Brochure or in the written agreement between Strathmore Capital and the client.