The firm’s advisory business was founded in 1984. Oppenheimer + Close, LLC, a Delaware limited liability company (“Oppenheimer + Close”), is a registered investment adviser. Oppvest LLC, a Delaware limited liability company (“Oppvest”), is an affiliated registered investment adviser owned and managed by the owners and managers of Oppenheimer + Close. Prior to September 2013 the firm’s business was conducted through Oppenheimer + Close, Inc., a New York corporation. The firm’s principal owner is Carl K. Oppenheimer. Advisory services for individually managed accounts Our focus is on “value” investing, and our horizon is long term. The majority of our research is conducted internally. Our primary focus is on exchange-listed or over-the- counter equity securities, both domestic and foreign. We use insured bank deposits and short-term Treasury issues for uninvested reserves. While we have not done so recently, we are not precluded from investing in warrants, corporate debt, municipal securities, exchange-traded funds, or money market funds if we perceive opportunity for profit at appropriate risk. We meet with and speak to clients regularly, and portfolios are tailored to the needs of individual clients. In general, clients will have the same portfolio holdings. Weightings may vary based on liquidity needs, timing of purchase, or other factors including risk tolerance and investment objectives. We generally attempt to accommodate investment restrictions imposed by clients (for example: an aversion to tobacco or casino companies). Due to recent changes in the laws relating to retirement plans, we no longer provide recommendations to clients to transfer the assets in their existing retirement plans or individual retirement accounts to other retirement plans or individual retirement accounts. Advisory services for pooled investment vehicles Oppvest manages three limited partnerships (two are hedged). Following is a brief description of each. P. Oppenheimer Investment Partnership, LP invests in undervalued securities and in securities issued by special-situation companies. Oppenheimer-Spence Financial Services Partnership, LP focuses its investment activities on publicly

traded issuers in the financial services industry, including, but not limited to, banks, savings and loan associations, securities brokerage firms, mutual fund management companies, insurance companies, credit unions, mortgage origination and service companies. Oppenheimer-Close Investment Partnership, LP invests opportunistically without focusing on any particular industry or geographic region, but limits investment in the financial services industry to no more than 7.5% of assets at the time of purchase. There is the same 7.5% restriction for investments in non-public companies and alternative assets. Subadvisors P. Oppenheimer Investment Partnership has engaged SCSP Capital Advisors to manage a segregated account capped at $1,000,000 established for the sole purpose of acquiring shares of a specific security. SCSP Capital Advisors has the power to manage the account for the limited purpose of purchasing, selling, exchanging, converting, and entering into trades or otherwise effecting transactions in the shares on behalf of the P. Oppenheimer Investment Partnership, LP. Brokerage services With few exceptions, our clients, including the pooled investment vehicles we manage, use the brokerage services of Pershing Advisor Solutions LLC, an affiliate of The Bank of New York Mellon Corp. Pershing Advisor Solutions LLC is an introducing broker- dealer that clears its transactions on a fully disclosed basis through Pershing LLC, an affiliate of Pershing Advisor Solutions LLC. Pershing LLC also acts as qualified custodian. Clients with individually managed accounts may elect to have their assets held at Pershing LLC or at the custodian of their choice. We do not participate in wrap fee programs. We do not publish research reports or sell newsletters. We do not normally use the term “financial planning”, but we do work with our clients’ accountants and attorneys when appropriate to discuss estate planning, generation skipping and tax efficiency. We conduct no other business. As of December 31, 2022, our assets under management were $208,200,000, of which $204,500,00 were assets managed on a discretionary basis and $3,700,000 were assets managed on a non-discretionary basis.