A. Description of the Advisory Firm Legacy Capital Wealth Partners, LLC (“Legacy Capital” or the “Advisor”) is a limited liability company organized in the State of Delaware. Legacy Capital became an investment advisory firm registered with the United States Securities and Exchange Commission (“SEC”) in February 2018. Legacy Capital is owned by Legacy Capital Wealth Holdings, LLC. The majority owners of Legacy Capital Wealth Holdings, LLC are Matthew Jones and Jason Prather. If you have any questions regarding the contents of this Disclosure Brochure, please do not hesitate to contact the Advisor’s Chief Compliance Officer, Bob Roberts by telephone at (501) 376-7878 or by email at [email protected]. B. Types of Advisory Services Legacy Capital provides holistic and personalized financial planning and discretionary and non- discretionary investment advisory services to individuals, high net worth individuals, families, family offices, trusts, estates, businesses, charitable foundations, nonprofit organizations and retirement/profit-sharing plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Legacy Capital’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Financial Planning and Consulting Services Legacy Capital offers financial planning and consulting services to Clients. Such engagements may be part of the investment advisory engagement or pursuant to a separate engagement. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to: cash flow analysis, investment planning, retirement planning, estate planning, personal savings, educational savings, and other areas of a Client’s financial situation. Clients are encouraged, but are not required, to engage Legacy Capital for financial planning or consulting services. A financial plan developed for or financial consultation rendered to the Client will typically include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Legacy Capital may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Legacy Capital recommends its own services, as such a recommendation may increase the advisory fees paid to Legacy Capital. The Client is under no obligation to act upon any of the recommendations made by Legacy Capital under a financial planning or consulting engagement to engage the services of any such recommended professional, including Legacy Capital itself. Investment Management Services Legacy Capital focuses on providing objective and holistic advice to Clients. In designing and implementing customized portfolio strategies, Legacy Capital can manage, on a discretionary or non-discretionary basis, a broad range of investment strategies and vehicles. Legacy Capital primarily allocates Client assets among various mutual funds, exchange-traded funds (“ETFs”), alternative investments, options, and individual debt and equity securities in accordance with the Client’s stated investment objectives. Legacy Capital may further recommend to Clients that all or a portion of their investment portfolio be managed on a discretionary basis by one or more unaffiliated money managers or investment platforms (“External Managers”). The Client may be required to enter into a separate agreement with the External Manager[s], which will set forth the terms and conditions of the Client’s engagement of the External Manager, or will receive a Statement of Investment Selection in a single contract relationship. Legacy Capital generally renders services to the Client relative to the discretionary selection of External Manager[s]. Legacy Capital also assists in establishing the Client’s investment objectives

for the assets managed by External Manager[s], monitors and reviews the account performance and defines any restrictions on the account. The investment management fees charged by the designated External Manager[s], together with the fees charged by the corresponding designated broker-dealer/custodian of the Client’s assets, may be exclusive of, and in addition to, the annual advisory fee charged by Legacy Capital. Comprehensive Management Services Based on the needs and objectives of the Client, Legacy may provide additional services and work closely with their respective accountant, attorney or another specialist, as appropriate to manage their unique situation, as needed, pursuant to the investment management agreement. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g., commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Retirement Plan Advisory Services Legacy Capital provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Investment Management Services (ERISA 3(38))
• Ongoing Investment Recommendation and Assistance These services are provided by Legacy Capital serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Legacy Capital’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Legacy Capital does not render tax or legal advice. C. Client-Tailored Advisory Services Legacy Capital seeks to provide personalized, tailored advisory services designed to meet the specific needs of each Client. Legacy Capital works collaboratively with its Clients, and any of its Clients’ outside advisors, including lawyers, accountants, and tax advisors, to meet its Clients’ goals. Client portfolios are managed on the basis of individual Clients’ financial situation and investment objectives. Clients may impose reasonable restrictions on the management of their accounts if Legacy Capital determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for Legacy Capital’s management efforts. D. Wrap Fee Programs For certain client relationships, Legacy includes securities transaction fees, custodial costs, administrative fees, wire fees, trade away transactions, other fees and expenses (herein “Covered Costs) together with its investment advisory fees. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its investment management services for its Clients. The Advisor sponsors the Legacy Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. E. Assets Under Management As of December 31, 2023, Legacy Capital manages approximately $1,128,118,401 in Client assets, of which $890,600,671 are managed on a discretionary basis and $237,517,730 on a non- discretionary basis.