DESCRIPTION OF SERVICES Southern Capital Advisors, LLC d/b/a FP360 (“SCA” or the “Firm”) is a registered investment adviser which has been in business since November 2017 and is principally owned by Charles L. Johnson. The firm is organized as a Limited Liability Company in the state of Tennessee. SCA offers ongoing portfolio management services, primarily discretionary and primarily through a wrap fee program. Details of this program can be found in our Wrap Fee Program Brochure. The Firm also offers non-wrap fee services (and non-discretionary services) which are discussed in this brochure. Clients are required to enter into an agreement for investment advisory services. At the onset of the agreement, clients participate in detailed discussions regarding goals and investment objectives, risk tolerance and time horizon, liquidity and cash flow needs, and other factors pertaining to the individual’s investment policy (and these are documented in the client’s Investment Policy Statement, or IPS). SCA, as part of the agreement, may requests discretion to manage investment portfolios in a manner consistent with the aforementioned policy (see “Portfolio Management Services” below for more details about the investment management process). In general, SCA does not utilize third-party managers, although we reserve that capability and may implement such strategies on an as-needed basis. In the event of such an arrangement, the fees shared with the third-party manager would be disclosed. PORTFOLIO MANAGEMENT SERVICES SCA offers discretionary and nondiscretionary portfolio management services based on the individual goals, objectives, time horizon, risk tolerance, liquidity, and cash flow needs of each client. SCA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that is appropriate for each client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring SCA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. SCA will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is provided to each client. SCA seeks to ensure that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of SCA’s economic, investment or other financial interests. To meet its fiduciary obligations, SCA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, SCA’s 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 SCA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. FINANCIAL PLANNING & CONSULTING SERVICES SCA may, separate from portfolio management services, engage in stand-alone arrangements for financial planning and/or consulting services. Financial planning and consulting services may include but are not limited to: general financial planning; investment and non-investment related planning; insurance planning;

tax concerns; retirement planning; college planning; debt/credit planning; retirement plan consulting; and business consulting. Prior to engaging the Firm to provide planning or consulting services, clients are generally required to enter into a Financial Planning Agreement with the Firm setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to the Firm commencing services. Clients may terminate the agreement without penalty, for full refund of SCA’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Agreement generally upon written request. PENSION/BENEFIT CONSULTING SERVICES SCA offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to:
• Plan design and policy construction
• Identifying investment objectives and restrictions
• Providing guidance on various assets classes and investment options
• Recommending money managers to manage plan assets in ways designed to achieve objectives
• Monitoring performance of money managers and investment options and making recommendations for changes o recommending other service providers, such as custodians, administrators and broker-dealers
• Creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. SERVICES GENERALLY LIMITED TO SPECIFIC TYPES OF INVESTMENTS SCA generally limits its investment advice to equities, mutual funds, fixed income securities, real estate funds (including REITs), ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds and non-U.S. securities, although SCA primarily recommends equities, mutual funds, and ETFs. SCA may use other securities as well to help diversify a portfolio when applicable. CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS SCA will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by SCA on behalf of the client. SCA may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent SCA from properly servicing the client account, or if the restrictions would require SCA to deviate from its standard suite of services, SCA reserves the right to end the relationship. WRAP FEE PROGRAM SCA acts as portfolio manager for and sponsor of a wrap fee program, which is an investment program where the client pays one state fee that includes management fees, transaction costs, fund expenses, and other administrative fees. However, this brochure describes SCA’s non-wrap fee advisory services; clients utilizing SCA’s wrap fee program should reference the separate Wrap Fee Program Brochure. SCA manages the investments in the wrap fee program but does not manage those wrap fee accounts any differently than it would manage non-wrap fee accounts. Fees paid under the wrap fee program will be given to SCA as management/advisory fees. Please also see Item 5 and Item 12 of this brochure for more information. AMOUNTS UNDER MANAGEMENT SCA has the following assets under management: Discretionary Assets Non-discretionary Assets Date Calculated $ 332,436,014.00 $ 132,736.00 December 2022