Camelotta Advisors provides individuals and other types of clients with a wide array of investment advisory services. The Firm is a corporation formed under the laws of the State of Texas and has been in business as an investment adviser since 2004. The Firm is wholly owned by Dana Grigg. The Firm provides portfolio management, advisory consulting and pension consulting for clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. As a fiduciary, it is the Firm’s duty to always act in the client’s best interest. This is accomplished in part by knowing the client. Camelotta Advisors has established a service-oriented advisory practice with open lines of communication. Working with clients to understand their investment objectives while educating them about the Firm’s process, facilitates the kind of working relationship the Firm values. Prior to Camelotta Advisors rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Camelotta Advisors setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). As of December 31, 2023, Camelotta Advisors had $181,187,395 assets under management, $180,181,774 of which was managed on a discretionary basis and $1,005,621 of which was managed on a non- discretionary basis. While this brochure generally describes the business of Camelotta Advisors, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or other persons who provide investment advice on Camelotta Advisors’s behalf and are subject to the Firm’s supervision or control. Portfolio Management As part of the Firm’s Portfolio Management service, clients will be provided with asset management and financial consulting services. This service is designed to assist clients in meeting their financial goals using a financial plan or consultation. The Firm conducts client meetings to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what is learned, an investment approach is presented to the client, consisting of individual stocks, bonds, ETFs, options, mutual funds and other public securities or investments. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. Camelotta Advisors manages client investment portfolios on a discretionary or non-discretionary basis upon client request, the Firm provides a summary of observations and recommendations for the planning or consulting aspects of this service. Page | 5 © MarketCounsel 2024 Advisory Consulting The Firm provides advisory consulting services to clients for the management of financial resources based upon an analysis of current situation, goals, and objectives. Advisory Consulting services will typically involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, or Business and Personal Consulting. Written financial plans or financial consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. Implementation of the recommendations will be at the discretion of the client. Camelotta Advisors provides clients with a summary of their financial situation, and observations for advisory consulting engagements. Financial consultations are not typically accompanied by a written summary of observations and recommendations, as the process is less formal than the planning service.

Assuming all the information and documents requested from the client are provided promptly, plans or consultations are typically completed within 6 months of the client signing a contract with our firm. Pension Consulting The Firm provides discretionary and non-discretionary pension plan consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include: investment options, plan structure. Retirement Plan Consulting services typically include:
• Establishing an Investment Policy Statement – The Firm will assist in the development of a statement that summarizes the investment goals and objectives along with the broad strategies to be employed to meet the objectives.
• Investment Options – The Firm will work with the Plan Sponsor to evaluate existing investment options and make recommendations for appropriate changes.
• Asset Allocation and Portfolio Construction – The Firm will develop strategic asset allocation models to aid Participants in developing strategies to meet their investment objectives, time horizon, financial situation and tolerance for risk.
• Investment Monitoring – The Firm will monitor the performance of the investments. In providing services for retirement plan consulting, the Firm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement plan Page | 6 © MarketCounsel 2024 consulting services shall comply with the applicable state laws regulating retirement consulting services. This applies to client accounts that are retirement or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein. In performing any of the aforementioned consulting or financial planning services, Camelotta Advisors is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Camelotta Advisors recommends certain clients engage the Firm for additional related services and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Camelotta Advisors or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Camelotta Advisors under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Camelotta Advisors’s recommendations and/or services. Tailoring of Advisory Services The Firm offers individualized investment advice to our Portfolio Management clients. General investment advice will be offered to our Advisory Consulting and Pension Consulting clients. Portfolio Management clients may place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account.