Service Academy Capital Management LLC, a Delaware limited liability company (“SACM” or the “Firm”), is an investment adviser registered with the states of California1, New York2, New Mexico3, Florida, Texas, and Illinois4 pursuant to the applicable state laws, rules and regulations (collectively, the “State Laws”). SACM has its principal place of business located in Texas. SACM was founded in 2015. Please note that registration with a state regulatory authority does not imply a certain level of skill or training. A. General Description of Advisory Firm Firm History SACM’s focus is to provide sound financial advice to its clients. Its intent is to have at least one graduate from one of the service academies – United States Naval Academy (the “USNA”), United States Air Force Academy (the “USAFA”), United States Military Academy/West Point (the “USMA”), United States Coast Guard Academy (the “USCGA”), and United States Merchant Marine Academy (the “USMMA”) on every team at the Firm. In addition, SACM is focused on hiring and training veterans for a career in financial services and returning a portion of the overall revenues of the Firm to veteran related charities. SACM traces its heritage to the 1980’s when its principal and manager, Brian Stephen Sears, was a midshipman at the USNA. See ADV Part 2B for additional background on the Firm and its manager. Firm Ownership 100% of Service Academy voting membership interests are owned individually by Mr. Sears. B. Description of Advisory Services SACM provides investment advisory services on a discretionary or non-discretionary basis to various types of clients as described below for a fee. Please refer to ITEM 7 for further information on the types of clients to which we provide our investment management services. Through personal discussions with the client, SACM determines the client’s objectives, time horizon, risk tolerance, and liquidity needs in order to establish goals and objectives for a bespoke investment portfolio. This service encompasses providing asset management as well as financial planning/financial consulting for clients. 1 Under the California Corporate Securities Law of 1968 and the regulations promulgated thereunder, the California

Corporations Code and the California Code of Regulations Title 10, Chapter 3, Subchapter 2, Article 10. 2 Under the New York Investment Advisory Act, Title 13 and the regulations promulgated thereunder, Part 11 New York Code of Rules and Regulations (NYCRR). 3 Under the New Mexico Uniform Securities Act, NMSA 58-13C and the regulations promulgated thereunder, the New Mexico Administrative Code, Title 12, Chapter 11, Part 5 12.11.5 NMAC. 4 Under the Illinois Securities Law of 1953, and the regulations promulgated thereunder, the Illinois Administrative Code, Section 130 ILAC subpart H. The development of an investment strategy for a client’s portfolio is a continuous process and, therefore, SACM’s strategy may be modified from time to time. Investment decisions require the exercise of judgment by SACM and might, as a result of outside market forces, deviate in some instances from the initial strategy proposed for the client. It is SACM’s desire to formally review the client’s investment portfolio with the client on an annual basis to ensure we are meeting the client’s current investment goals. If the client experiences any significant changes to his/her financial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. Prior to SACM providing investment management services, the client will be required to enter into an Investment Management Agreement with SACM (the “IMA”) setting forth the terms and conditions under which SACM shall manage the client’s assets, as well as a separate custodial/clearing agreement with the broker-dealer/custodian (See, ITEM 12 – Brokerage Practices). The IMA authorizes the broker- dealer/custodian to debit the account for the amount of SACM’s investment management fee and to directly remit that management fee to SACM in accordance with required State Law procedures and any other applicable state authority procedures. Separately Managed Accounts The allocation of assets can include the use of one or more separately managed accounts managed by SACM. Investments in an account can include: mutual funds (open end and closed end), Exchange Traded Funds (ETFs), Limited Partnerships (LP), exchange funds and direct ownership of equities, fixed income and other capital markets investments based on the individual needs of the client. Selection of Other Advisers SACM may direct clients to third-party investment advisers. Before selecting other advisers for clients, SACM will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where SACM is recommending the adviser to clients. Client Assets Under Management SACM has $337,697,844 million in client assets under management on a discretionary basis.