5 High Velocity Asset Backed Securities (ABS)/Mortgage-Backed Securities (MBS) Strategy: DCM will manage a portfolio of new issues ABS/MBS bonds. The portfolio will be managed for short-term capital gains. DCM looks to add value through tactical, active management of the portfolio by monitoring market data and technical information coupled with analysis of underlying collateral, issuers and structure in both primary and secondary markets when determining how to invest. Primary focus will be within Investment Grad securities with Weighted Average Life (WAL) of 5 years or less, although on occasion non-investment grade or longer duration may be considered. The strategy generates short-term capital gains and should not be confused with a strategy holding ABS/MBS bonds long-term for income and/or total return. Turnover (velocity) in the portfolio is extremely high – in excess of 1,000%. The strategy will also utilize leverage of greater than 100% which poses high risks as leverage magnifies trading losses, in addition to the risk inherent in leverage, there is liquidity risk associated with these securities as short-term liquidity is dependent on a marketplace without a robust, central exchange. Currently, there are no non-affiliated investors in this strategy, and it is not available to advisory clients at this time. Daily, DCM monitors the new issue ABS/MBS bonds which the strategy has indicated interest in. If the strategy has indicated for the same new issue which another strategy or client has also indicated interest in, the High Velocity ABS/MBS strategy will seek to either remove its indications of interest with the underwriters or in the event that it is unable to remove its indications of interest and is allocated bonds will allocate those bonds to clients who have indicated interest. This will be done to ensure that the strategy does not conflict with DCM clients. Registered Investment Companies DCM also serves as investment adviser with respect to the DCM/INNOVA High Equity Income Innovation Fund (“DCM/INNOVA Fund”), the Copley Fund, and Lebenthal Ultra Short Tax-Free Income Fund, each a series of shares of the Centaur Mutual Funds Trust, an open-end management investment company, registered under the Investment Company Act of 1940, as amended (the “Trust”). The Trust is referred to in this document as “DCM- Managed Funds.” DCM manages the investment and reinvestment of the assets of the DCM-Managed Funds and has the authority to determine, in its discretion, the securities to be purchased, retained, or sold (and implement those decisions) with respect to the DCM-Managed Funds. DCM is required to discharge its responsibilities with respect to the DCM-Managed Funds subject to the control of the trustees and directors of the DCM-Managed Funds and in compliance with such policies as the trustees and directors may from time to time establish, the DCM-Managed Funds’ objectives, policies and limitations as set forth in its prospectus and statement of additional information, and applicable laws and regulations. Model Portfolio Services DCM provides portfolio modeling services to registered investment advisers on a non-discretionary basis. As part of the arrangement, DCM offers recommendations in accordance with the investment objectives stated in the investment advisory agreement. The registered investment advisers utilize these recommendations to develop their own investment advice and strategies. DCM’s recommendations are not tailored to the individual needs of the registered investment adviser’s clients. Furthermore, DCM does not affect transactions in the client accounts and has no contact with the clients. The services provided by DCM to registered investment advisers generally differ from services provided to other clients that engage DCM directly; DCM provides a higher degree of service to its clients. For example, DCM generally has little, if any, contact with the clients of the registered investment advisers that utilize DCM’s model portfolio services. Subscription Services In addition to these asset management and investment advisory services, DCM (through its Heckman Global Advisors

group (“HGA”)) issues several monthly research publications regarding country allocation and sector/industry analysis based on a series of factors. This group does not provide security-specific research. Furthermore, the content of HGA’s publications are not tailored to the individual needs of clients. Institutional global allocators comprise the subscriber base for the HGA research publications. Description of Wealth Advisory Services DCM also provides investment advisory services which may include, but are not limited to, the review of client investment objectives and goals, recommending asset allocation strategies of managed assets among investment products such as cash, stocks, mutual funds and bonds, annuities, and/or preparing written investment strategies. DCM’s investment advice is tailored to meet its clients’ needs and investment objectives. Clients may impose restrictions on investing in certain securities or types of securities (such as a product type, specific companies, specific sectors, specific values (ESG), etc.) by providing a signed and dated written notification, of which an email is also an acceptable form of notification. DCM also provides financial planning consulting services including, but not limited to, risk assessment/management, investment planning, estate planning, financial organization, or financial decision making/negotiation. DCM provides investment advisory and other financial services through its Investment Advisory Representatives (“IAR”) to accounts opened with DCM. Managed Accounts are available to individuals and small businesses. In the event that DCM provides discretionary investment advisory services to its clients through various managed account programs, DCM will assist clients in determining the suitability of the managed account programs for the client. The IAR would be compensated through a single fee for wealth advisory and asset management services and the account may be assessed other charges associated with conducting a brokerage business. DCM and its IAR, as appropriate, generally would be responsible for the following:
• Performing due diligence
• Recommending strategic asset and style allocations
• Providing research on investment product options, as needed
• Providing client risk profile questionnaire
• Obtaining investment advisory contract from client with required financial, risk tolerance, suitability, and investment vehicle selection information for each new account
• Performing client suitability check on account documentation, review the investment objectives and evaluate the investment vehicle selections
• Providing the Brochure Assets Under Management DCM currently has assets under management. As of December 31, 2023, the firm managed $349,795,018, all in discretionary accounts. All DCM asset-based advisory fees are subject to negotiation. The specific manner in which DCM charges fees is established in a client’s written agreement with DCM and may be payable in advance or in arrears. Depending on the services provided, a particular client may pay a blended fee rate. DCM does not offer fixed fee accounts. The following types of fees will be assessed: Asset-Based Compensation DCM generally charges each client an investment management fee based on the value of the client’s assets under management, in accordance with the following schedules: DCM All Cap Strategy Assets in the Account Investment Management Fee (As an annual percentage of total assets) First $5,000,000 0.80% Next $10,000,000 Next $25,000,000 Next $40,000,000 0.75% 0.68% 0.60% Remainder 0.52% DCM Large Cap Value Strategy Assets in the Account Investment Management Fee (As an annual percentage of total assets) First $25,000,000 0.75% Remainder 0.60% Fixed-Income Strategies Assets in the Account Investment Management Fee (As an annual percentage of total assets) $ -0- to $2,000,000 0.50% $2,000,001 to $5,000,000 0.45% $5,000,001 to $10,000,000 $10,000,001 and higher 0.40% 0.25%