CSPAM is an SEC registered investment adviser and a limited liability company formed under the laws of, and headquartered in, the state of Virginia. Registration does not imply a certain level of skill or training. The Firm is a wholly owned subsidiary of CSPF. As of December 31, 2023, CSPAM had $1,358,565,924in assets under management on a discretionary basis and $122,892,298 in assets under management on a non-discretionary basis. CSPAM provides third-party asset management for clients of registered investment advisers (“Advisors”) through advisory programs (“Programs”) at various custodians on a discretionary basis. In addition, CSPAM provides advisory and sub-advisory investment management services to clients of affiliated and unaffiliated Advisors who have engaged with CSPAM. In limited circumstances, we provide our services directly to retail and institutional clients, but generally all services are provided through the Advisors, who then interact with the clients. Prior to CSPAM providing investment management services, the end-client will be required to enter into a formal agreement with CSPAM, setting forth the terms and conditions under which assets will be managed. The investment management agreement may authorize the broker-dealer/custodian to debit the account for CSPAM’s investment management fee and to directly remit that management fee to CSPAM. As part of the process, the Advisor will obtain information sufficient to determine the client’s financial situation and investment objectives and further assist the client in selecting an appropriate portfolio based on the client’s financial plan. In performing its services, CSPAM is not required to verify information (such as investment objectives and limitations) received from the client, their Advisor, or other professionals; and CSPAM is authorized to rely on the information provided from the Advisor. The following process is generally applicable to CSPAM’s management of client assets: 1.Initial Interview – at the opening of the account, CSPAM, through your Advisor, will obtain from you, information sufficient to determine your financial situation and investment objectives; 2.Individual Treatment - your account is managed based on your financial situation and investment objectives; Consultation Available – CSPAM and your Advisor shall be reasonably available to consult with the client relative to the status of their account(s); 3.Quarterly Statement from Custodian – You will be provided with a statement, at least quarterly, that is prepared by the custodian and directly delivered from the custodian; that statement is the official record of your client account(s) and shall contain a description of all trade activity in the client account(s) during the preceding period; 4.Termination – The investment management agreement between CSPAM and the client and/or Advisor will continue in effect unless terminated by either party by written notice in accordance with the terms and conditions of the investment management agreement; 5.Tax Sensitivity -- CSPAM will also help manage a client’s tax sensitivity as directed by the client’s Advisor-- This includes, but is not limited to, selling mutual funds ahead of capital gain distributions and replacing with ETFs for a period sufficient to avoid wash sales, and selling securities in an unrealized loss position to offset realized capital gains; and 6.Separate Account - a separate account or accounts will be maintained for you with the custodian.
March 2024 Firm Brochure Part 2A Page 5 Other Types of Advisory Services Proprietary Exchange Traded Fund CSPAM serves as the investment adviser of the Fairlead Tactical Sector ETF (“TACK”), a diversified, actively managed exchange- traded fund (“ETF”) that invests in passive domestic equity sector ETFs and ETFs investing in gold and U.S. Treasuries. Fairlead Strategies, an unaffiliated third-party, serves as TACK’s Subadviser. Investment Consulting Services CSPAM also provides investment consulting services for individuals and institutions on a non-discretionary basis. CSPAM provides investment consulting services that relate to matters such as allocation of assets among different classes, portfolio diversification, managing portfolio risk, portfolio monitoring/evaluation, and other general economic and financial topics. Account supervision is guided by the stated objectives of the client. CSPAM does not generally provide legal or accounting services, so no portion of your consultation with CSPAM should be interpreted as legal or accounting advice. At a client’s request, CSPAM will

provide professional references in legal, accounting, and other associated areas. Types of Investment Programs CSP Global and CSP Active Management CSPAM provides investment management services through its service offerings: CSP Global and CSP Active Management. CSP Global provides investment strategies using primarily shares of mutual funds and exchange-traded funds (ETFs), and separately managed accounts (SMAs); while CSP Active Management provides investment management strategies primarily utilizing individual equity and fixed income securities. Both CSP Global and CSP Active Management offer multiple investment strategies through advisory programs on a discretionary basis. Additional information as to the specific investments and other portfolio composition characteristics and metrics underlying each program strategy are provided to the end-client and the Advisor in advance of the execution of the strategy or strategies by CSPAM. Wrap Fee Programs CSPAM provides investment strategy services and is the Portfolio Manager of various wrap fee programs, each sponsored by various registered investment advisers (“Sponsor(s)”). Please review the Sponsor’s Wrap Fee Brochure (Form ADV Part 2A Wrap Fee Brochure) for a complete description of its services, fees and any account minimums regarding its wrap fee program. CSPAM manages specific investment strategies in wrap fee programs for both non-discretionary Model and discretionary Wrap Account programs sponsored by unaffiliated financial institutions similar to its management of the same strategies implemented in its CSP Global portfolios for example. In both the Wrap Account/Model programs however, CSPAM personnel primarily support the financial institution sponsoring the wrap program and not the actual underlying client. There are fundamental differences between a Wrap Account and Model program. In a traditional Wrap Account program, a client selects the Sponsor. The Sponsor will work with the client to select an approved discretionary investment adviser, like CSPAM, for a particular investment strategy. From time to time, the Sponsor will communicate any specific client needs/requests to CSPAM, and CSPAM will evaluate for reasonableness within the strategy. CSPAM relies on the Sponsor to gather the necessary information and assess the suitability of its investment style to the individual needs and financial situation of a Wrap Account client. For Wrap Accounts, CSPAM exercises investment discretion and delivers buy/sell instructions to the Sponsor’s platform. The Sponsor is responsible for execution of each transaction in the client accounts. Under the Model programs, depending on the model, the Sponsor or its designated representative, sometimes referred to as an “overlay manager,” exercises investment discretion and executes each client’s portfolio transactions based on the Sponsor’s March 2024 Firm Brochure Part 2A Page 6 own investment judgment. CSPAM does not tailor the model portfolio to the individual needs of any program client. CSPAM does not evaluate suitability for clients in a Model program. In both types of wrap sponsored programs, the Sponsor provides a bundle of services for a single fee. Typically, this bundle of services includes the review and monitoring of selected investment advisers approved in the program, performance evaluation of the adviser, execution of the client’s portfolio transactions, custodial services of the client’s assets and payment of CSPAM’s advisory fee and other fees that may be charged in the Sponsor’s program. The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated with managing the account, and the frequency or type of securities transactions executed in the account.
• For example, a wrap fee program is not suitable for all accounts, including, but not limited to, accounts holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income securities or no- transaction-fee mutual funds, or any other type of security that can be traded without commissions or other transaction fees.
• In order to evaluate whether a wrap (or bundled) fee arrangement is appropriate for you, you should compare the agreed-upon Wrap Program Fee and any other costs associated with participating in our Wrap Fee Program with the amounts that would be charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and execution costs, and custodial services comparable to those provided under the Wrap Fee Program.