Description of Services and Fees We are a registered investment adviser based in Naples, Florida. We are organized as a limited liability company and we have been providing investment advisory services since 2011. Pasquale (Pat) Antonetti Jr. is the sole owner of ACM through the Pat Antonetti, Jr. Revocable Living Trust. Currently, we offer portfolio management and financial planning services which are personalized to each individual client. The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we", "our", "us", and “Advisor” refer to ACM and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person throughout this brochure. As used in this brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm. Our Investment Adviser Representative(s) (“IAR(s)”) may market under a business name of their choosing. When they do this, they may have their own legal business entities whose business names and logos appear on marketing materials. The client should understand that the businesses are legal entities of the IAR and not of ACM. However, Investment Advisory Services of the IARs are provided through ACM. Additional information about our arrangement with the IARs can be found on the ADV Part 2B, also referred to as the brochure supplement which contains information about the educational background, business experience, and disciplinary history (if any) of the IARs who provide advisory services to the client. Portfolio Management Services We offer discretionary and non-discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, investment time horizon and other relevant information (the "suitability information") at the beginning of our advisory relationship. We will use the suitability information we gather to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf. As part of our portfolio management services, we may customize an investment portfolio for you in accordance with your risk tolerance and investing objectives. We may also invest your assets according to one or more model portfolios developed by our firm. Once we construct an investment portfolio for you, or select a model portfolio, we will monitor your portfolio's performance on an ongoing basis and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances. You should keep us informed of any changes in your financial or personal circumstances that could affect our management of your assets. The Client agrees to permit Advisor to consult with and obtain information from his/her accountant and/or attorney, which may be relevant in development of and maintaining the Client’s Account(s). It is at the Advisor’s discretion to determine the value of the information received from the Client’s accountant and/or attorney, and the Advisor is under no obligation to rely solely on this information. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. Our fee for discretionary portfolio management services is based on a percentage of assets we manage and is set forth in the following fee schedules: Market Value of Account Quarterly Annualized Fee*** (Discretionary - Global Total Return) $ 1 - $1,000,000 0.2500% 1.00% $1,000,001 - $2,000,000 0.2250% 0.90% $2,000,001 - $3,000,000 0.2000% 0.80% $3,000,001 - $4,000,000 0.1750% 0.70% $4,000,001 - $5,000,000 0.1500% 0.60% $5,000,001 - 0.1250% 0.50% Market Value of Account Annualized Fee*** (Discretionary - Customized) Entire market value of account 1.00% For non-discretionary portfolio management services, we charge a fee of $100 per quarter which fee may be waived in our sole discretion. This fee

is billed in advance. *** Some clients may pay fees lower than those stated above. The fee schedules are not blended meaning you will be charged the specified percentage fee on the value of your entire account not just the value within the tier. We require our annual portfolio management fee for discretionary accounts to be billed and payable quarterly in advance based on the value of your account on the last day of the previous quarter. If the portfolio management agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Our advisory fee is negotiable, depending on individual client circumstances. Therefore, clients with similar assets under management and investment objectives may pay significantly higher or lower fees than other clients. At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in your paying Market Value of Account Annualized Fee*** (Discretionary - Fixed Income Only) $100,000 - $2,000,000 0.50% $2,000,001 - $5,000,000 0.40% $5,000,001 - $10,000,000 0.30% Assets in excess of $10 million 0.20% a reduced advisory fee based on the available breakpoints in our fee schedule stated above. You can choose to pay our advisory fee directly or we will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy. You may terminate the portfolio management agreement upon written notice to our firm. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees, by check or credit back to your account, in proportion to the number of days in the quarter for which you were a client. The Client has the right to terminate this Agreement without penalty within five (5) business days after entering into this Agreement. Thereafter, either party upon thirty (30) days written notice may terminate this Agreement at any time. This allows the Advisor sufficient time to finalize transactions and enable the delivery of final statements and release of documents. In the event of termination after five (5) business days from the execution of this Agreement or at any time other than the end of a calendar quarter, Client will be entitled to a pro-rated refund of any prepaid quarterly advisory fee based upon the number of days remaining in the quarter after receipt of written notice of cancellation. Types of Investments We primarily offer advice on mutual funds, exchange traded funds, equity securities, corporate debt securities, commercial paper, municipal securities, U.S. Government securities and options. Additionally, we may advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Assets Under Management As of December 31, 2022, we manage $ 120,173,761.00 in client assets on a discretionary basis and have $ 3,832,612.00 in client assets on a non-discretionary basis.