A. Firm Description Valor Capital Management was formed in Delaware on October 6, 2017 as a limited liability company and is 100% owned by C2P Enterprises, LLC. Valor’s registration with the Securities and Exchange Commission became effective on March 1, 2018. The Firm’s principal place of business is in Westlake, OH. The Firm is led by Jason L Smith, Chief Executive Officer, and David Alison, President and Founding Partner. B. Types of Advisory Services Valor operates as a Turnkey Asset Manager Program (“TAMP”), Sub-advisor, Co-Advisor and/or Fund Strategist providing asset management and administrative services which are utilized by registered investment advisers, broker-dealers, and other financial institutions (collectively “Separate Advisors”) for the benefit of their Clients. 1. TAMP Services The TAMP investment services provided by Valor include but are not limited to client billing services, rebalancing, due diligence activities, serving as an operational liaison between the Separate Advisors and custodians, various portfolio management tools, transaction data processing, making available quarterly account reports, training, retaining and providing access to certain third-party investment managers and research, and other administration and support services. The services may be completed internally or through affiliated and non-affiliated third parties. Client accounts are administered on a discretionary basis pursuant to instructions received from the Client or Client’s Separate Advisor’s Investment Advisory Agreement allowing Valor and/or third-party investment managers to act on their behalf. Specific TAMP offerings include separately managed accounts, signal-based relationships and AdvisorSelect Portfolios as more fully described below. Separately Managed Accounts (SMA) and Signal Based Relationships As part of Valor’s TAMP offering, Valor retains and provides access to certain third-party investment managers to design and manage model portfolios called separately managed accounts (“SMAs”). The SMA investment manager, not Valor or the Separate Advisor, is responsible for all investment and reinvestment-related decisions and trade execution in the Client accounts. However, while SMA investment managers regularly monitor the SMA accounts and are responsible for managing the model portfolios on behalf of Valor and the Separate Advisor, the SMA is not acting as your investment advisor and does not possess knowledge of your individual information or investment goals and objectives. Separate Advisors may recommend that their Clients, where suitable, authorize the active discretionary management of all or a portion of their assets by and/or among selected SMAs, based upon the stated investment objectives and risk profile of the Client. Clients will receive Valor’s disclosure brochure and other related documents as well as the SMA’s and Separate Advisor’s disclosure brochure and related documents. Each SMA is uniquely structured so please ensure you carefully review the applicable SMA’s disclosure brochure to understand their investment strategy, how they operate, the fees they charge, how investments will be managed, risk profile, among other matters. Depending on the SMA selected, the client may need to authorize the SMA to vote proxies on their behalf. Valor conducts the initial due diligence on SMAs and performs administrative, operational, and other support services for which it charges a platform fee as discussed below. Valor also enters into signal-based relationships with certain third-party managers whereby it makes available their model asset allocation portfolios on Valor’s TAMP. These third-party managers typically called Signal Providers monitor their respective models and provide Valor with ongoing recommendations for the allocation and reallocation of assets in the model consistent with the stated strategy. Different selected signal-based strategies and models will be sleeved within one account so that the Separate Advisor’s Client does not have to open multiple accounts. The Separate Advisor’s client will receive the most recent copy of the sleeved third- party strategy/model manager’s Form ADV brochure which outlines the strategy, risks, associated fees and other pertinent information. Valor does not typically reject or deviate from the trade signals provided by the Signal Provider. However, Separate Advisor’s clients will not achieve the same performance returns as shown in a Signal Provider’s marketing material and fact sheets if their accounts do not execute trades in strict conformance with the Signal Provider’s trade signals. Valor conducts the initial due diligence on these strategies/models and performs administrative, trade order management and execution, operational and other support services for which it charges a platform fee as discussed below. AdviserSelect Portfolios A Separate Adviser also has the ability to build and manage one or more customized individual investment portfolios for their Clients (“AdvisorSelect Portfolios”). The Separate Advisor is solely responsible for determining investment selections and giving instructions for trades, reinvestments and rebalances. Valor Capital does not provide any investment advice to AdviserSelect Portfolios, does not have or exercise any discretionary authority with regard to AdviserSelect Portfolios, and does not supervise the AdviserSelect Portfolios or the Separate Advisor in its management of AdviserSelect Portfolios. Please review the Separate Adviser’s disclosure brochure for additional information regarding the Separate Adviser’s management of customized investment portfolios. Valor provides operational support for AdviserSelect Portfolios and requires the Client’s authorization to perform services such as deducting fees and/or providing other services on Separate Advisor’s behalf. Valor’s platform fee will be charged to the Client account, in addition to the Separate Adviser’s investment advisory fee. Other Managers 2. Sub-advisory and Co-advisory Services With respect to its Sub-advisory and Co-advisory services, Valor has aligned with investment management companies including BlackRock, Dimensional Fund Advisors, The Vanguard Group, and others to provide its Separate Advisors an investment platform of core portfolio models and specialized strategies to meet the unique needs of their investment adviser representatives (“IARs”) and Clients. Valor’s core models provide strategic investment management through a diverse selection of risk- based asset allocation model portfolios. Specifically, Valor’s core models are generally comprised of exchange-traded funds (“ETFs”) and/or mutual funds designed to provide asset class diversification

for varying levels of risk tolerance on a pre-tax or post-tax basis. The DFA core models are managed in a manner substantially similar to the models historically developed and recommended for investment by Valor’s affiliate, C2P Capital Advisory Group, LLC dba Prosperity Capital Advisors, LLC (“PCA”). Valor also offers specialized strategies that are designed to complement Valor’s core model by offering unique or specific investment strategies and solutions. Specialized strategies are managed by Valor and/or third parties and may invest in stocks, bonds, mutual funds, ETFs or other securities in accordance with the investment objectives of the particular strategy. Leveraging one or more of the core and specialized models, Valor helps Separate Advisors and their IARs navigate the right investment offering, blended portfolio design, and operational implementation to meet the specific needs of their clients. Underlying Client accounts are generally managed based on the overall model, rather than specifically to each Client’s individual needs. However, with respect to Valor’s tax managed portfolios, Separate Advisors may from time to time provide Valor trade instructions to address specific Client circumstances. Valor will generally review the model portfolios quarterly for rebalancing designed to keep the portfolios consistent with the Firm’s usual and customary target parameters. Valor, the Separate Advisor, or the Client may elect not to rebalance for a number of reasons including, for example, consideration of a tax strategy, the funds involved are economically insufficient, additional fees and expenses are anticipated, or there are other pending events impacting the decision. Valor enters into sub-advisory or co-advisory agreements with Separate Advisors, whereby Valor invests client assets according to the Valor model portfolio selected by the Separate Advisor and Client. The Separate Advisor and their Clients execute a separate investment advisory agreement, and the Separate Advisor is responsible for providing the Client with individualized discretionary investment management services. The Separate Advisor serves as the primary relationship contact with the client and is responsible for determining the Client’s risk profile and for selecting the Valor model portfolios that are consistent with the Client’s risk profile. Clients should carefully review the investment management agreement executed with the Separate Advisor, as well as the Separate Advisor’s ADV Part 2A - Disclosure Brochure, for a full description of the services to be provided by the Separate Advisor. Under the Sub-Advisor or Co-Advisor Agreement, in addition to asset management services, Valor Capital provides non-advisory services including assistance in account administration, assistance in trading, billing and record keeping, and performance reporting as requested. Valor is provided with a limited power of attorney, by the Separate Advisor and the Client, to arrange for execution of trades and rebalancing of model portfolios. Valor is not responsible for ensuring that the model portfolios are consistent with a Client’s risk profile. Further, Valor will not serve as an investment advisor to individual Clients. Additionally, Valor has established agreements to work with a third-party investment adviser in a sub-advisory or investment research capacity. The sub-advisor is responsible for all investment- related decisions and trading in the client accounts. The subadvisor may be limited to only manage assets through specific custodians. For more information about what custodians a specific sub- advisor is authorized to offer services through, please refer to the sub-advisor’s ADV. There will be additional fees for the use of the sub-advisor. Please review the sub-advisor’s ADV for more information. Valor retains the authority to hire and fire sub-advisors at our discretion. 3. Strategist Services Valor also provides investment advisory services on a discretionary basis as a Fund Strategist for unified management accounts (“UMA”) by providing one or more its model portfolio strategies to a “Platform Provider”, such as Axxcess Wealth Management and Lockwood. Valor has entered into an agreement as a model manager with the Platform Provider. Valor provides access to some or all of its model portfolio strategies via the Platform Provider’s model management system for which Separate Advisors and Clients can then select for use in a Client account. For UMA managed accounts, Valor is solely responsible for the management of the model portfolio strategies provided to the Platform Provider which have been selected for use in a Client account by a Separate Advisor and/or Client. By utilizing one or more of Valor’s model portfolio strategies via a Platform Provider, the services Valor provides UMA/SMA managed accounts are limited to the following: portfolio design, asset allocation, risk management and security selection. UMA accounts are managed based on the selected portfolio’s stated investment strategy, philosophy, and objective, rather than on each Client’s individual needs. C. Client Tailored Services and Client Imposed Restrictions Valor manages a selection of model portfolios that are utilized by Separate Advisors. The portfolios are based on target asset-class allocations that designate specified percentages within multiple securities asset-classes with the intent of creating a diversified investment portfolio of no load institutional mutual funds, ETFs, equities, and fixed income solutions. These models are designed to provide asset class diversification for varying levels of risk tolerance. As a general matter, the models are to be used by Separate Advisors to help clients meet their investment goals, as determined by the Separate Advisor based on their client’s circumstances including investment needs, goals, objectives, risk tolerance, and time horizon. Client accounts are tailored to the client’s specific individual investment goals and objectives. The IAR of the Separate Advisor collects financial and personal information from the client, and then client and the IAR decide on an asset allocation strategy. The Firm does not maintain a direct relationship with Clients; however, Clients may impose certain reasonable restrictions on the management of their accounts through consultation with Separate Advisors. Nonetheless, Valor may determine that it cannot accept certain restrictions in its sole discretion. D. Wrap Fee Programs Valor Capital does not sponsor or manage a wrap fee program. E. Amounts of Assets Under Management As of December 31, 2022, the Firm had $892,788,709 in assets under management and an additional $460,969 in assets under advisement.