Donoghue Forlines LLC (hereafter “we,” “us”, “Donoghue Forlines” or the “Company”) is a fee-based investment advisory firm that offers portfolio management services. The Company is a Delaware Limited Liability Company and commenced operations as an investment adviser in 1986. The Company is majority- owned by WEDCO Acquisition Co., LLC, which is owned and controlled by David A. Minella, through his ownership of Minella Capital Management, LLC. Minority ownership stakes in the Company are held by certain principals and former principals of the Company. We provide discretionary account management to individuals, corporations and institutions, and serve as an investment adviser and sub-adviser to mutual funds and ETFs. Model mutual fund, individual equity, and exchange-traded fund (“ETF”) investment portfolios are developed and serve as the basis to meet specific investor needs for risk-adjusted returns and comprise our dynamic asset allocation portfolios and index portfolios. We combine quantitative analysis and technical research from both proprietary and external sources in developing and maintaining our investment strategies. We apply principles of investment diversification, as well as technical indicators, across broad market segments in an effort to reduce overall portfolio risk while improving potential investment returns. We employ rules and technically-based screening/analysis to evaluate portfolio holdings and to assist in the selection process. We continuously monitor the financial markets for signs of relative strength or weakness. When a decision is made to shift assets, both instructions regarding execution of orders and execution of orders for all accounts with similar investment objectives are made generally the same day. Some ETF holdings in these portfolios trade like stocks so that brokerage trading fees or asset-based pricing fees will apply in addition to advisory fees assessed by the Company. In addition, some mutual fund classes of shares have transaction fees. Each custodian has its own pricing schedule. As of December 31, 2023, our combined regulatory assets under management and assets under advisement were $733 million. Regulatory assets under management were approximately $376 million. In addition, we provide model portfolios and related trading signals to third-party financial advisers who use these models and trading signals to manage their client accounts. The firm maintained these model portfolio arrangements with approximately 18 firms and platforms. These assets under advisement were approximately $357 million. Our regulatory assets under management include approximately $248 million allocated through our model portfolios and funds of funds to mutual funds we advise or ETFs that we sub-advise. These assets are included in both the regulatory assets under management and the assets under advisement presented above. Our client accounts are invested in exchange traded securities, investment companies (including exchange traded funds) and cash and equivalents (including money market funds). PORTFOLIOS The Company provides discretionary account management services in accordance with the asset allocation portfolios described below. Clients have the opportunity to impose reasonable restrictions on the investments made in their accounts, regardless of the portfolio selected. The Company also provides access to its model portfolios to other Registered Investment Advisers and Broker-Dealers. Recommendations for changes to the model portfolios are generally made monthly or as needed and communicated after the close of the market. Donoghue Forlines Blended Portfolios Donoghue Forlines Income Portfolio: The Donoghue Forlines Income Portfolio has the objective of maximizing total return from income and capital appreciation with the preservation of capital a secondary objective. The portfolio seeks returns with limited risk and seeks to beat an index of all bonds, corporate and government securities. The portfolio invests in the mutual funds and ETFs advised or sub-advised by Donoghue Forlines (currently Donoghue Forlines Tactical Income Fund, Donoghue Forlines Risk Managed Income Fund, Donoghue Forlines Dividend Fund, Donoghue Forlines Tactical High Yield ETF), and other fixed income investment options. A proprietary defensive trading system, used for a portion of the assets, indicates whether it is time to be invested in the funds or defensively positioned in treasuries or money markets. Since this strategy will invest exclusively in mutual funds and ETFs advised or sub-advised by Donoghue Forlines, no additional fee will be charged by Donoghue Forlines for managing the portfolio to mitigate conflicts of interest. As with any investment in a pooled investment vehicle, investors will incur indirectly the fees and expenses of the underlying funds and ETFs in addition to fees and expenses charged by their broker or advisor. The portfolio is an appropriate choice for investors who are seeking current income with capital preservation as a secondary objective. Donoghue Forlines Growth & Income Portfolio: The Donoghue Forlines Growth & Income Portfolio primarily seeks growth and income using a diversified investment strategy which employs a combination of global macro fundamental and technical analysis. The strategy will invest in one or more of the following funds: Donoghue Forlines Tactical Allocation Fund; Donoghue Forlines Tactical Income Fund; Donoghue Forlines Dividend Fund; Donoghue Forlines Momentum Fund; and Donoghue Forlines Risk Managed Income Fund. Many of these investments carry a tactical overlay that will shift assets to short‐term U.S. Treasury ETFs or cash equivalents predicated upon technical indicators. Since this strategy will invest exclusively in mutual funds advised by Donoghue Forlines, no additional fee will be charged by Donoghue Forlines for managing the portfolio and to mitigate conflicts of interest. As with any investment in a pooled investment vehicle, investors will incur indirectly the fees and expenses of the underlying funds and ETFs in addition to fees and expenses charged by their broker or advisor. The Donoghue Forlines Growth & Income Portfolio as a standalone strategy is appropriate for investors with a moderate risk tolerance. The portfolio is suitable for investors with a longer-term time horizon of 5-10 years or more. The strategy is designed to preserve capital during periods of market weakness by investing more heavily in fixed income asset classes and cash. Donoghue Forlines Dividend & Yield Portfolio: The Donoghue Forlines Dividend & Yield Portfolio primarily seeks income and growth using a diversified investment strategy which employs a combination of global macro fundamental and technical analysis. The strategy will invest in one or more of the following funds: Donoghue Forlines Tactical Allocation Fund; Donoghue Forlines Tactical Income Fund; Donoghue Forlines Dividend Fund; Donoghue Forlines Momentum Fund; and Donoghue Forlines Risk Managed Income Fund. Many of these investments carry a tactical overlay that will shift assets to short‐term U.S. Treasury ETFs or cash equivalents predicated upon technical indicators. Since this strategy will invest exclusively in mutual funds advised by Donoghue Forlines, no additional fee will be charged by Donoghue Forlines for managing the portfolio to minimize potential conflicts of interest. As with any investment in a pooled investment vehicle, investors will incur indirectly the fees and expenses of the underlying funds and ETFs in addition to fees and expenses charged by their broker or advisor. The Donoghue Forlines Dividend & Yield Portfolio is suitable for investors with a relatively short time horizon who may be drawing income from the portfolio. The strategy is designed to preserve capital during periods of market weakness by investing more heavily in fixed income asset classes. In addition, the portfolio strategy will employ tactical investment strategies to attempt to control downside volatility by moving toward defensive short-term U.S. Treasury ETFs or money market positions when the market warrants it. The portfolio primarily seeks income and growth from investment assets. Donoghue Forlines Rules Based Portfolios Donoghue Forlines Dividend Portfolio: The Donoghue Forlines Dividend Portfolio seeks to track the FCF Risk Managed Sector Neutral Dividend Index (the “Dividend Index”) (for more information regarding the Dividend Index, see Market Indexes section below). It has the objective of maximizing total return from income and capital appreciation with the preservation of capital as a secondary objective. The portfolio is a rules-based strategy that employs a disciplined investment selection process with tactical overlays that determines whether the portfolio will be in a bullish (invested) or defensive position. The tactical overlays are made up of two triggers to identify potentially negative intermediate‐term trends and that more broadly measure the health of the economy and monitor longer term evolving problems that could lead to bear markets or recessions. Based on the status of each tactical indicator, the Index could be 100% in equities, 50% in equities and 50% defensive, or 100% defensive. When in a defensive position, the Portfolio will invest in short‐term U.S. Treasury ETFs, money market funds or cash equivalents. When bullish, the Portfolio invests in up to 50 stocks. The stocks are selected based on having the highest dividend yields in their sector as well as meeting other quality factors. The Donoghue Forlines Dividend Portfolio as a standalone strategy is appropriate for investors with a high- risk tolerance. The strategy is generally suggested to be a portion of an overall portfolio and used to reduce equity drawdown. The portfolio is suitable for investors with a time horizon of five years or longer, as it can exhibit short-term volatility equal to or potentially greater than the overall stock market. Donoghue Forlines Dividend Mid-Cap Portfolio: The Donoghue Forlines Dividend Mid‐Cap Portfolio seeks to track the Donoghue Forlines Dividend Mid-Cap model. It has the objective of maximizing total return from income and capital appreciation with the preservation of capital a secondary objective. The portfolio implements a rules‐based strategy that employs an intermediate‐term tactical overlay driven by technical signals to determine whether the Portfolio will be in a bullish or defensive position. When in a defensive position, the Portfolio will be invested in short‐term U.S. Treasury ETFs. When bullish, the Portfolio is equally weighted across a portfolio of 50 stocks with the highest dividend yields from a proprietary universe of mid- cap stocks. The Donoghue Forlines Dividend Mid-Cap Portfolio as a standalone strategy is appropriate for investors with a high-risk tolerance. The strategy is generally suggested to be a portion of an overall portfolio and used to reduce equity drawdown. The portfolio is suitable for investors with a time horizon of five years or longer, as it can exhibit short-term volatility equal to or potentially greater than the overall stock market. The Donoghue Forlines Dividend Mid-Cap Portfolio strategy is currently closed to new investors. Donoghue Forlines Momentum Portfolio: The Donoghue Forlines Momentum Portfolio seeks to track the FCF Risk Managed Sector Neutral Momentum Index (the “Momentum Index”) (for more information regarding the Momentum Index, see Market Indexes section below). It has the objective of maximizing total return from income and capital appreciation with the preservation of capital a secondary objective. The portfolio is a rules-based strategy that employs a disciplined investment selection process with tactical overlays that determines whether the portfolio will be in a bullish (invested) or defensive position. The tactical overlays are made up of two triggers to identify potentially negative intermediate‐term trends and that more broadly measure the health of the economy and monitor longer term evolving problems that could lead to bear markets or recessions. Based on the status of each tactical indicator, the Index could be 100% in equities, 50% in equities and 50% defensive, or 100% defensive. When in a defensive position, the Portfolio will invest in short‐term U.S. Treasury ETFs, money market funds or cash equivalents. When bullish, the Portfolio invests in up to 50 stocks. The stocks are selected based on having the risk adjusted trailing momentum in their sector as well as meeting other quality factors. The Donoghue Forlines Momentum Portfolio as a standalone strategy is appropriate for investors with a high- risk tolerance. The strategy is generally suggested to be a portion of an overall portfolio and used to reduce equity drawdown. The portfolio is suitable for investors with a time horizon of five years or longer, as it can exhibit short-term volatility equal to or potentially greater than the overall stock market. Donoghue Forlines Treasury Portfolio: The Donoghue Forlines Treasury Portfolio seeks to track the Donoghue Forlines rules-based treasury strategy. The portfolio utilizes tactical shifts between long‐term and intermediate-term Treasuries to provide an optimized return stream with actively managed risk. Historically, the strategy has shown a negative correlation to the S&P 500. The portfolio uses credit sensitive tactical signals that identify crossover points of varying exponential moving averages in a group of underlying securities our research team has identified as providing consistent data in relation to shifts in the Treasury market. During negative credit conditions, the portfolio allocates into longer duration Treasury Bond ETFs, and when a more defensive position is warranted as credit conditions improve, the portfolio shifts investments into short to intermediate term Treasury Bond ETFs. The Donoghue Forlines Treasury Portfolio is suitable for investors with a relatively intermediate term time horizon who may be drawing income from the portfolio. The strategy is generally suggested to be combined with other fixed income strategies or within an overall more diversified portfolio. The portfolio primarily seeks income and growth from investment assets. Donoghue Forlines Thematic Portfolios DF Veridien Climate Action Portfolio: The strategy seeks to deliver a diversified, yet high conviction, portfolio of stocks by investing in global companies that are benefiting from the decarbonization megatrend. Applying a rigorous valuation process to these companies, we strive to deliver attractive risk adjusted returns in most economic environments. The secular tailwinds, which we consider a multi-decade megatrend, are bolstered by changing generational priorities, government subsidies and heightened focus on climate change, all of which make this an attractive and durable investment strategy. The DF Veridien Climate Action Portfolio is suitable for investors seeking growth and climate action impact. The strategy is generally suggested to be combined with other strategies or within an overall more diversified portfolio. The portfolio primarily seeks growth from global equity assets. Donoghue Forlines Global Tactical Product Suite

The Donoghue Forlines Global Tactical Product Suite offers Advisors and their clients the opportunity to implement a managed mutual fund and exchange traded fund (“ETF”) portfolio. Donoghue Forlines provides fund selection and asset allocation services through its Global Tactical Product Suite. These services are different from and in addition to the investment management services provided by an underlying fund’s investment manager. As with any investment in a pooled investment vehicle, investors will incur indirectly the fees and expenses of the underlying funds and ETFs in addition to fees and expenses charged by their broker or advisor. The portfolios generally include funds or ETFs advised or sub-advised by Donoghue Forlines or with whose investment advisor Donoghue Forlines has a joint marketing or other relationship and Donoghue Forlines receives fees from the adviser of those funds or ETFs. Certain brokers or advisors pays Donoghue Forlines a fee for the fund selection and asset allocation services related to the Global Tactical Product Suite. Donoghue Forlines Global Tactical Allocation (“GTA”) Portfolio: GTA is designed to be a core, long- term investment, presenting moderate growth potential and risk management across all asset classes. This strategy seeks to lower costs and volatility, while producing long-term capital appreciation. This strategy seeks to achieve moderate capital appreciation while using its tactical nature to preserve capital during times of market stress and invests across three asset classes: equities, fixed income and alternatives with a global orientation. The strategy is unconstrained and treats cash as a tactical asset class to help preserve capital and can raise cash levels as a defensive measure against volatile market downturns. This is the “flagship” portfolio of the Donoghue Forlines Global Tactical Product Suite and employs the main strategic and tactical approaches. It is a core portfolio that contains three asset classes in one brokerage account-equities, fixed income and alternatives (commodities and hard assets) through investment in mutual funds, exchange traded funds (ETFs) or other exchange traded products. The strategy targets long term global macro-economic trends while utilizing shorter term economic variables in analyzing potential price movements in the three main asset classes. The GTA portfolio holds fixed income investments in almost all market conditions, but has immense flexibility in holding equities, alternatives and cash. As a result, the level of investment risk in this portfolio may be lower than similar moderate allocation strategies. GTA employs larger and more frequent shifts in asset allocation to the modern volatile investment environment. Donoghue Forlines Global Tactical Income (“GTI”) Portfolio: GTI seeks to deliver high current income while preserving principal. As a secondary goal, the portfolio also seeks conservative capital appreciation. Concerns about the bond market and potential for rising interest rates make it timely to consider this portfolio. The strategy seeks to provide high current income and preservation of principal, while taking advantage of market opportunities to achieve conservative capital appreciation. It invests in funds and ETFs across three asset classes – primarily fixed income and alternatives, and to a much lesser extent equities. The strategy is unconstrained and treats cash as a tactical asset class to help preserve capital and can raise cash levels as a defensive measure against volatile market downturns. Donoghue Forlines Global Tactical Conservative (“GTC”) Portfolio: GTC is designed to be a core, long- term investment, presenting conservative growth potential and risk management across all asset classes. This strategy seeks to achieve conservative capital appreciation while emphasizing preservation of capital. The Strategy seeks to achieve conservative capital appreciation with an emphasis on preservation of capital by investing across three asset classes: equities, fixed income and alternatives with a global orientation through investment in funds and ETFs or other exchange traded products. The strategy is unconstrained and treats cash as a tactical asset class to help preserve capital and can raise cash levels as a defensive measure against volatile market downturns. Donoghue Forlines Global Tactical Growth (“GTG”) Portfolio: GTG is designed to be a core, long-term investment, presenting growth potential and risk management across all asset classes. This strategy seeks to achieve greater capital appreciation than GTA. while using its tactical nature to preserve capital. It invests in funds and ETFs across three asset classes: equities, fixed income and alternatives with a global orientation. The strategy is unconstrained and treats cash as a tactical asset class to help preserve capital and can raise cash levels as a defensive measure against volatile market downturns. Donoghue Forlines Global Tactical Equity (“GTE”) Portfolio: GTE is designed to be a core, long-term investment, presenting growth potential and risk management across all asset classes. It is a core portfolio that contains three asset classes in one account: equities, and to a much less extent fixed income and alternatives (commodities, real estate and hard assets). The macro top-down approach strategy targets long-term global macro-economic trends while analyzing shorter-term economic variables in assessing potential price movements in the three main asset classes, while GTE focuses on our best equity ideas. The GTE portfolio invests in funds and ETFs across three asset classes – primarily equity, and to a much lesser extent fixed income and alternative investments. It holds equity investments in almost all market conditions. It holds fixed income and alternatives investments for diversification and to lower standard deviations. MUTUAL FUNDS and EXCHANGE TRADED FUNDS (ETFs) The Company acts as adviser or sub-adviser to a number of mutual funds and ETFs described below. Investors in the mutual funds and ETFs that the Company advises do not have the option to impose restrictions on the funds’ investments. Donoghue Forlines Tactical Allocation Fund: This mutual fund is a series of Northern Lights Fund Trust. The Fund’s investment strategy is predicated upon the Donoghue Forlines Global Tactical Allocation Portfolio, described above. The Fund may hold proxy (or substitute) positions when compared to the Portfolio. The Donoghue Forlines Tactical Allocation Fund’s investment objectives and principal investment strategies are described in the Fund’s prospectus. Donoghue Forlines Tactical Income Fund: This mutual fund is a series of Northern Lights Fund Trust. The Fund’s investment objectives and principal investment strategies are described in the Fund’s prospectus. Donoghue Forlines Dividend Fund: This mutual fund is a series of Northern Lights Fund Trust. This fund is predicated upon our proprietary FCF Risk Managed Sector Neutral Dividend Index, described below. The Donoghue Forlines Dividend Fund’s investment objectives and principal investment strategies are described in the Fund’s prospectus. Donoghue Forlines Momentum Fund: This mutual fund is a series of Northern Lights Fund Trust. This fund is predicated upon our proprietary FCF Risk Managed Sector Neutral Momentum Index, described below. The Donoghue Forlines Momentum Fund’s investment objectives and principal investment strategies are described in the Fund’s prospectus. Donoghue Forlines Risk Managed Income Fund: This mutual fund is a series of Northern Lights Fund Trust. This fund is predicated upon our proprietary Donoghue Forlines Floating Rate model, described below. The Donoghue Forlines Risk Managed Income Fund’s investment objectives and principal investment strategies are described in the Fund’s prospectus. Donoghue Forlines Innovation ETF (DFNV): This ETF is a series of TrimTabs ETF Trust. This fund is predicated upon the FCF Quality Innovation Index. The ETF’s investment objectives and principal investment strategies are described in its prospectus. Donoghue Forlines Tactical High Yield ETF (DFHY): This ETF is a series of TrimTabs ETF Trust. This fund is predicated upon the FCF Tactical High Yield Index. The ETF’s investment objectives and principal investment strategies are described in its prospectus. Donoghue Forlines Yield Enhanced Real Asset ETF (DFRA): This ETF is a series of TrimTabs ETF Trust. This fund is predicated upon the FCF Yield Enhanced Real Asset Index. The ETF’s investment objectives and principal investment strategies are described in its prospectus. VARIABLE INSURANCE TRUST (VIT) FUNDS Donoghue Forlines Dividend VIT Fund: This mutual fund is a series of the Northern Lights Variable Trust, a Delaware statutory trust designed to be a funding vehicle for variable annuity contracts and flexible premium variable life insurance policies offered by separate accounts of various insurance companies. Its shares are sold to those separate accounts and pension and retirement plans that qualify for special income tax treatment. Shares of the Donoghue Forlines Dividend VIT Fund are not offered directly to the general public. Individual variable annuity contract holders and flexible premium variable life insurance policyholders are not shareholders of the Donoghue Forlines Dividend VIT Fund. However, clients of the Company are also holders of variable annuity contracts and variable life insurance policies whose separate accounts invest in the Donoghue Forlines Dividend VIT Fund. This fund is predicated upon our proprietary FCF Risk Managed Sector Neutral Dividend Index, described below. The Donoghue Forlines Dividend VIT Fund’s investment objectives and principal investment strategies are described in the Fund’s prospectus. Donoghue Forlines Momentum VIT Fund: This mutual fund is a series of the Northern Lights Variable Trust, a Delaware statutory trust designed to be a funding vehicle for variable annuity contracts and flexible premium variable life insurance policies offered by separate accounts of various insurance companies. Its shares are sold to those separate accounts and pension and retirement plans that qualify for special income tax treatment. Shares of the Donoghue Forlines Momentum VIT Fund are not offered directly to the general public. Individual variable annuity contract holders and flexible premium variable life insurance policyholders are not shareholders of the Donoghue Forlines Momentum VIT Fund. However, clients of the Company are also holders of variable annuity contracts and variable life insurance policies whose separate accounts invest in the Donoghue Forlines Momentum VIT Fund. This fund is predicated upon our proprietary FCF Risk Managed Sector Neutral Momentum Index, described below. The Donoghue Forlines Momentum VIT Fund’s investment objectives and principal investment strategies are described in the Fund’s prospectus. MARKET INDEXES Donoghue Forlines has developed certain indexes in coordination with FCF Indexes LLC. For these indexes Donoghue Forlines provides certain methodology, FCF Indexes LLC, an affiliate of FCF Advisors LLC, provides day to day control and oversight, and INDXX serves as calculating agent. These indexes are used exclusively by Donoghue Forlines in the management of its portfolios, funds and other accounts. FCF Risk Managed Sector Neutral Dividend Index: The index tracks the performance of a rules-based strategy that seeks to provide downside-protected exposure to U.S. equities with strong Free Cash Flow and Dividend Yield, selected by a proprietary Free Cash Flow and Dividend Yield factor model. The index directs between 50% and 100% of its position into short-term U.S. Treasury during a defensive stance. FCF Risk Managed Sector Neutral Momentum Index: The index tracks the performance of a rules-based strategy that seeks to provide downside-protected exposure to U.S. equities with strong Free Cash Flow and positive Momentum, selected by a proprietary Free Cash Flow and Momentum factor model. The index directs between 50% and 100% of its position into short-term U.S. Treasury during a defensive stance. FCF Quality Innovation Index: The index tracks the performance of a rules-based strategy that seeks to provide exposure to U.S. equities with strong Free Cash Flow and R&D Investment, selected by a proprietary Free Cash Flow Innovation factor model. FCF Tactical High Yield Index: The index tracks the performance of a rules-based tactical strategy that employs technical signals to determine a bullish or defensive posture: when bullish, the Index is fully invested into selected High Yield Bond exchange-traded funds (“ETFs”); when defensive, the Index directs 80% of its position into selected intermediate-term U.S. Treasury ETFs. FCF US High Yield Bond Index: The index tracks the performance of a rules-based strategy that seeks to provide exposure to U.S. High Yield Bond. The index invests in a selection of U.S. High Yield Bond ETFs, based on a proprietary model using expense ratios and assets under management. FCF US Intermediate Treasury Index: The index tracks the performance of a rules-based strategy that seeks to provide exposure to U.S. Intermediate Treasuries. The index invests in a selection of U.S. Intermediate Treasury ETFs, based on a proprietary model using expense ratios and assets under management. FCF US Short-Term Treasury Index: The index tracks the performance of a rules-based strategy that seeks to provide exposure to U.S. Short-Term Treasuries. The index invests in a selection of U.S. Short-Term Treasury ETFs, based on a proprietary model using expense ratio and assets under management. ASSET MANAGEMENT We provide investment management services to clients through various channels. We manage proprietary mutual funds and select individually managed accounts and sub-advise ETFs on a discretionary basis, but the majority of our strategies are offered to end clients on separately managed account and 401k platforms sponsored by Registered Investment Advisory firms and Broker-Dealers (“Platforms”) for a fee based on a percentage of assets under management. In most cases, the Company does not have a relationship with the end-clients using the Company’s models, as the relationships are generally with the Platforms and/or the advisers and broker-dealers. Variations in the fee may occur depending on the relationship between the Company and the adviser or broker-dealer introducing the client. Any such variations are disclosed and agreed to in the client’s investment advisory agreement. The majority of accounts are managed in accordance with model portfolios selected by the Platforms. We and the Platforms agree that they may “customize” their investment alternatives by providing “reasonable restrictions” to exclude from the investment alternatives as held by the client’s account(s) certain types of classes or categories of securities or industries. We allow clients to change the direction with respect to the investment of their accounts and/or rebalance the holdings in their accounts daily. If a client requests these modifications, there may be a greater need for liquidity in the portfolios than we would otherwise maintain.