RPM Capital Management, LLC is a privately owned registered investment advisor specializing in the acquisition, analysis, and ongoing management of high yield tax-exempt municipal bonds and dividend paying equity holdings. RPM Capital Management has been in business since June 2012. The firmMichele M. Newland. Tracy Abbott is the Chief Compliance Officer. RPM Capital Management manages assets through two investment strategies which are more fully described in Item 8. These asset management services are available to accredited investors, as such term is defined in Rule 501 of Regulation D. Clients are predominately individuals and their affiliated trusts, foundations, and family offices. RPM Capital Management requires each client seeking investment management services to place at least $500,000 under management. The firm may waive this account minimum requirement under certain circumstances, in our discretion. investment strategies, asset management services are almost always RPM Capital Management is engaged to provide asset management services on a discretionary basis, we will monitor your accounts and make changes as needed in keeping with the RPM investment strategies. These changes may involve selling a security or group of securities and buying others or keeping certain proceeds in cash. You may receive at your request written or electronic confirmations from your account custodian after any changes are made to your account. You will also receive statements at least quarterly from your account custodian. Clients engaging us on a discretionary

basis will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) as well as an investment management agreement that outlines the responsibilities of both the client and RPM Capital Management. As an accommodation only, and not on a regular basis, RPM Capital Management may provide asset -When a client engages us to provide investment management services on a non-discretionary basis, changes to your account will not be made until we have confirmed with you verbally or in writing that our proposed change is acceptable to you. free bonds and equities. RPM Capital Management has an expertise in the origination, due diligence, structuring, and monitoring of tax-exempt and taxable municipal bonds. Tax-exempt bonds can generate cash flow free from federal income tax, and, in certain instances, free also from state and local income tax. Further, this benefit compounds as income from the tax free bonds is reinvested again into other tax free bonds, thereby taking a potentially increased return and investing it into another security with a potentially increased return. Because the strategies are designed to be run as a single investment strategy, clients are not permitted to make significant restrictions to the management of their assets with RPM Capital Management. RPM Capital Management does not participate in or offer or sponsor a wrap program. As of December 31, 2023, RPM Capital Management has approximately $85,941,067 in total assets under management.