A. Firm Description Summa was formed in January 2001 and is owned by Maria Luisa Bernaldo de Quiroz, who serves as the President and Chief Compliance Officer. B. Types of Advisory Services Summa provides investment advice, supervisory services, consulting and family office services to its clients by advising and/or effecting purchases and sales of equities, options, debt instruments, governmental securities, hedge funds and/or mutual fund shares in or for its clients’ accounts which will provide proper diversification and help meet the client’s stated investment objectives. Summa provides its clients discretionary and non-discretionary account services tailored to each client’s needs. Summa offers its investment services on non-wrap fee basis. For non-discretionary accounts, Summa makes written or oral investment recommendations to client or client’s designee. Client and or client’s designee is under no obligation to act upon Summa’s recommendations. Client may also direct Summa to make specific investments in client’s account. Notwithstanding the Summa’s policy on fair and equitable allocation of investment opportunities, transactions effected on behalf of a client to for whom Summa has discretionary trading authority may be effected prior to the time that recommendations for transactions in the same securities may be communicated to clients with non-discretionary accounts and at different prices. Any client may impose restrictions on his or her account but any such restrictions must be provided in writing. Summa provides Portfolio Consulting Services on a non-discretionary basis as a financial consultant, to provide general investment advice and regular supervisory and management services, regarding those Assets designated by Client. To the extent mutual funds are selected to fill components of the overall investment strategy, the annual advisory fee set forth above does not include the customary fees and expenses associated with investing in mutual funds or other costs of establishing and

maintaining an account with mutual funds including Rule 12b-1 fees and expenses. Client is advised that, in addition to the annual advisory fee set forth above, each mutual fund in which assets are invested will incur separate investment advisory fees and other expenses for which client will bear a proportionate share. The relationship between the parties may be terminated by either party upon 30 days’ written notice. Notwithstanding the above, if the appropriate disclosure statement was not delivered to the client at least 48 hours prior to client entering into any written or oral advisory contract with this investment adviser, then client has the right to terminate the relationship, contract without penalty, within five business days after entering into the contract. In the event of termination, the advisory fee due to the Adviser for the termination period shall be prorated and shall be based on the latest valuation of the assets as of the date notice was received; and will be refunded within two weeks of termination. The Firm has entered into a Non-Discretionary agreement with Summa Asset Management Inc., a Panamanian register investment advisor, wherein The Firm will act as sub-advisor for certain of the of the Summa Asset Management Inc clients. C. Client Tailored Services and Client Imposed Restrictions Summa obtains financial and other information from each client which enables it to tailor its advisory services to the individual needs of each client. Clients may impose restrictions as to the type of securities utilized in their accounts by providing such restrictions to Summa in writing. D. Wrap Fee Programs Summa does not sponsor or manage a wrap fee program. E. Amounts of Assets under Management Summa manages client assets on both a discretionary and non-discretionary basis. As of December 31, 2023 the Firm had approximately $361,619,046 in total assets under management, of which approximately $266,092,975 was managed on a discretionary basis and $95,526,071 was managed on a non-discretionary basis.