Description of the Advisory Firm LotusGroup Advisors, LLC (after this "LotusGroup" or "LGA") is a privately held Registered Investment Advisor company that was formed on December 22, 2006, and is organized as a limited liability company under the laws of the State of Colorado. The Firm has been in business since January 2007. It is principally owned by Raphael A. Martorello, Managing Partner (85.7%), Andleib "Andy" Seth, Partner (9.5%), Nicholas S. Pirnack, Partner and Senior Advisor (2.9%), and Stephanie L. Schlemeyer, Partner and Product Manager (1.8%). LGA is authorized to do business in any state but also has specific registrations in the states of California, Colorado, New Hampshire, New York., and Texas. (Please refer to Form ADV Part 2B for details of their formal education and business background.) Types of Advisory Services LotusGroup offers the following services to advisory clients: Financial Planning & Portfolio Management LotusGroup Advisors offers financial planning services and advice, investment advisory and portfolio management services for private clients, solicited clients, and companies (all collectively called "clients" going forward in this document) through a Full Trading Authorization and a Limited Power of Attorney. LotusGroup Advisor's minimum asset requirement for new clients is generally $500,000. LotusGroup Advisors may make an exception to the minimum asset requirement at its sole discretion. Although this practice is highly recommended for ongoing savings, asset allocation, and tax efficiency, there are no ongoing contribution requirements. Clients undergo an introductory interview to outline their financial situation and help LotusGroup Advisors set risk tolerance and investment objectives. Clients then choose a portfolio strategy based on their risk profile, investor behavior profile, liquidity needs, and the amount of assets that LotusGroup Advisors will be managing on their behalf. Clients select one of six risk profiles: aggressive, moderate-aggressive, moderate, conservative-moderate, conservative, and ultra-conservative, and choose one of six portfolio strategies based on behavior profile and assets: emerging, global index, global rotation, tactical active, tactical absolute, and private investment only. LotusGroup Advisors meets with clients periodically to review their financial situation, answer questions, and determine if adjustments are needed relative to their financial objectives, risk tolerance, and time horizon. For individual clients who have expressed interest, we offer a complimentary financial planning service to help them make major life decisions and track how they are doing against their goals on an ongoing basis. LotusGroup Advisors may, at times, manage and advise on client assets applicable to ERISA. Such instances may include IRA accounts and other plans that are not subject to ERISA but are subject to section 4975 of the Internal Revenue Code. LotusGroup Advisors understands that, as a manager or potential manager of ERISA, plan assets, and/or as a manager for assets subject to section 4975 of the Internal Revenue Code, the Firm and its supervised persons must satisfy ERISA’s fiduciary standards. LotusGroup Advisors does not participate in wrap fee programs by providing portfolio management services and, therefore, receives no portion of a wrap fee for LGA services. LotusGroup Advisors may pay referral fees to solicitors in exchange for client referrals; at this time, no such relationship exists. LotusGroup Advisors provides the above services,

managing $226,619,872 in client assets, $160,163,730 on a discretionary basis, and $66,456,142 on a non-discretionary basis as of December 31, 2023. LotusGroup Advisors performs daily management activities within the guidelines of an Investment Policy Statement ("IPS") without day- to-day client consultation (known as "discretionary" management of assets). All funds are held in a client's account at an independent brokerage firm(s), and each client authorizes invoices to be paid from their account(s). Also, LotusGroup provides:
• Account setup and transfers to a selected Broker/Custodian,
• Development of a Client Investment Policy Statement ("IPS"), along with a personalized savings & investment program,
• Discretionary selection of specific investments within the program,
• Periodic adjustment of the asset allocation model within the stated client's category grouping and risk profile,
• Weekly administration of portfolio rebalancing as assets move outside of a specified target range,
• Production and distribution of individual quarterly performance reports,
• Production and delivery of client newsletters,
• Ongoing reviews and updates of client goal trackers,
• Personalized advice and analysis to assist in making good decisions,
• Sourcing, negotiation, and sharing of private investment opportunities enable accredited clients to select the opportunity they would like to participate in, the amount they would like to invest, and an account in which they would like to invest. (The aforementioned is LGA's "non-discretionary" investment management business, wherein each client chooses investments for themselves, with LGA providing access, advice, and ongoing updates. These services are only available for clients that are self-determined as "Accredited" investors.)
• Support in setting up 401K plans for small business owners and investment fund line-up evaluation and selection services. Business Valuation Services LGA offers business valuation services to current and prospective clients of the Firm. These business valuations are administered by a Certified Exit Planning Advisor (“CEPA”) at the Firm. These services are targeted to be provided to sophisticated business owners across many industries, including, but not limited to, accounting, finance, trades, goods manufacturing, consultation services, energy exploration, midstream energy services, retail stores, and other small and mid-size businesses. Business valuation clients will undergo initial meetings and interviews with LGA to identify the intention of the valuation, such as for a sale of the entity or for other means, and the tentative time horizon for any such actions based on the finalizing of the valuation opinion by LGA. The completion of LGA’s valuation opinion will vary depending on the availability of information from the business owner but typically takes between four (4) and eight (8) weeks to complete. Client Tailored Services & Client Imposed Restrictions LGA offers the same suite of services to all its clients. In rare cases, a client can request that LGA does not sell specific legacy securities (e.g., an inherited stock with large capital appreciation). Clients can impose restrictions on investing in certain securities or types of securities by their values or beliefs. However, if the restrictions prevent LGA from adequately servicing the client account or if the limits require LGA to deviate from its standard suite of services, LGA reserves the right to end the relationship.