a) Description of the Advisory Firm Palm Springs Advisory LLC (hereinafter “Palm Springs Advisory” or “PSA”) was founded as a Delaware Limited Liability Company in 2017 and 100% employee owned. Palm Springs Advisory devotes its resources primarily to the service of high-net worth individuals, qualified clients, and non-U.S. resident clients. Palm Springs Advisory provides fixed and tailored strategies for a variety of client accounts. Palm Springs Advisory primarily focuses on getting rid of the technology revolution to searching investment opportunities that could benefit clients in the long term. b) Services Provided Palm Springs Advisory offers two types of portfolio management services and will request discretionary authority from clients to select securities and execute transactions without permission from the client prior to each transaction. Palm Springs Advisory evaluates (either through face-to-face interview or internet questionnaire filling) current investments of each client with respect to their risk tolerance levels and time horizon. According to client’s preference and risk tolerance, one of the following investment service policy statements is provided. Clients choose the type of services and proportion of their investment toward different investment services. According to the client’s individual goals, objectives, time horizon, and risk tolerance, Palm Springs Advisory offers one of the following portfolio management services: 1. Technology Growth Portfolio Management Services: Palm Springs Advisory offers the same suite of services to all of its clients, who choose this type of service. Investment will be more focused on large capitalization technology firms. 2. Lifecycle Portfolio Management Services: Palm Springs Advisory offers the same suite of services to all of its clients who choose this type of service. Investments will be more focused on those companies that meet the needs of everybody’s whole lifecycle. 3. Family Office Services: Palm Springs Advisory provide all consultancy and investment services to high-net-worth families. Services include, but are not limited to, taxation consultant, risk management, registry services etc. Portfolio management services include, but are not limited to, the following:
• Investment strategy formation
• Asset allocation
• Risk tolerance.
• Personal investment policy
• Asset selection
• Regular portfolio monitoring All the portfolio management services above are recommended for an investment period of at least three (3) years, however, 5-10 years is preferable. PSA primarily recommends equities to a majority of its clients, and when applicable, can use other security instruments to help diversify a portfolio. Clients must set up an account with Interactive Brokers LLC and provide written contractual authority to Palm Springs Advisory to trade on behalf of clients. Palm Springs Advisory doesn’t receive any commissions or any remuneration for clients who open and maintain an account with Interactive Brokers. Clients may instruct Palm Springs Advisory to close their position and withdraw from account by given a written notice at least 30 days before withdrawal. Palm Springs Advisory may close the required position at any time during the 30-day period based upon its understanding to the market. Palm Springs Advisory seeks to provide investment decisions that are made in accordance with the fiduciary duties owed

to its client’s and without consideration of Palm Springs Advisory’s economic, investment, or other financial interests. To meet its fiduciary obligations, Palm Springs Advisory attempt to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Palm Springs Advisory’ policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Palm Springs Advisory’ policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, fairly among its clients on a fair and equitable basis. (c) Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. Palm Springs Advisory does not participate in any wrap fee programs. (d) Other Business Activities Palm Spring Advisory does offer fixed and variable annuity financial products primarily to non- resident and non-citizens of the United States of America. The Firm’s standard investment management contract generally permits either party to terminate immediately upon written notice to the other party. The management fee will be pro-rated to the date of termination, for the quarter in which the cancellation notice was given and the unearned fee refunded to the Client’s account, or any earned fee will be billed to the Client. Upon termination, a Client is responsible for monitoring the securities in his or her account, and we will have no further obligation to act or advise with respect to those assets. In the event of Client’s death or disability, Palm Springs will continue management of the account until we are notified of Client’s death or disability and given alternative instructions by an authorized party. In summary, Palm Springs provides the following advisory services:
• Discretionary Investment Management, except as otherwise set forth in any applicable Client Agreement. Our clients authorize Palm Springs to investigate, purchase, and sell on behalf of Client, various securities and investments. The Company is authorized to execute purchases and sales of securities on Client’s behalf without consulting Client regarding each sale or purchase. Client may, however, terminate the discretionary authority of Palm Springs immediately upon written notice.
• The Company possesses the ability to work with a client on establishing an Investment Policy Statement. In this scenario, Palm Springs, in connection with the Client, may develop a statement that summarizes the Client’s investment goals and objectives along with the broad strategy[ies] to be employed to meet the objectives. When the Company serves as investment adviser, it enters into a written investment management agreement with each of its advisory Clients. Investment management agreements include provisions related to each Client’s management fees, investment strategy, investment guidelines, termination rights, proxy voting and sub- adviser, if applicable. Upon termination, Clients are billed only for the pro-rata portion of the management period. Clients do not pay a termination fee. (e) Clients Assets Under Management As of December 31, 2023, TCWM has $ 1,659, 074 assets under management on a discretionary basis and $ 0.00 on a non-discretionary basis.