A. Description of the Advisory Firm Lazari Capital Management, Inc. (hereinafter “LCMI”) is a corporation that was formed in August 2014, and the principal owner is Michael Lazari Karapetian. LCMI provides services to individuals, trusts, high-net-worth individuals, pension and profit- sharing plans, and corporations or business entities concerning equities, fixed income securities, real estate funds (including REITs), ETFs (including ETFs in the gold and precious metal sectors), options, treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements mutual funds insurance products including annuities. As a registered investment adviser, we are held to the highest standard of client care – a fiduciary standard. As a fiduciary, we always put our client’s interests first and must fully disclose any potential conflict of interest. We do not hold customer funds or securities. B. Types of Advisory Services Portfolio Management Services LCMI offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. LCMI creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). 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 LCMI evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. LCMI 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 given to each client. LCMI seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of LCMI’s economic, investment or other financial interests. To meet its fiduciary obligations, LCMI attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, LCMI’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 LCMI’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. Pension Consulting Services LCMI offers ongoing consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans) based on the demographics, goals, objectives, time horizon, and/or risk tolerance of the plan’s participants. LCMI is currently accepting rollover transfers, and provide management

services to pensions, and 401(k). LCMI will utilize third parties for 401(k) business. Services Limited to Specific Types of Investments LCMI generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements. LCMI may use other securities as well to help diversify a portfolio when applicable. Financial Planning and Estate Planning Financial plans and financial planning may include but are not limited to estate planning; investment planning; life insurance; tax concerns; retirement planning; education planning; and debt/credit planning. 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. C. Client Tailored Services and Client Imposed Restrictions LCMI offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). 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 LCMI from properly servicing the client account, or if the restrictions would require LCMI to deviate from its standard suite of services, LCMI reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. LCMI does not participate in any wrap fee programs. E. Assets Under Management As of December 31, 2023, LCMI has the following assets under management: Discretionary Amounts Non-Discretionary Amounts Date Calculated $ 363,731,801 $ 107,417,862 December 31, 2023