A. Firm Information Alsworth Capital Management, LLC (“ACM” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a limited liability company (“LLC”) under the laws of New York. ACM was founded in August 2015 and became a registered investment advisor in November 2015. ACM is owned and operated by Shane M. Alsworth (Chief Executive Officer and Financial Advisor) and Jacqueline Alsworth (Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by ACM. B. Advisory Services Offered ACM offers investment advisory services to individuals, high net worth individuals, trusts, estates and charitable organizations, corporations and retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. ACM’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services ACM provides Clients with comprehensive wealth management services, which generally includes a broad range of comprehensive financial planning and consulting services in connection with discretionary management of investment portfolios. ACM works closely with each Client to identify their investment goals and objectives, as well as risk tolerance and financial situation in order to create a portfolio strategy and a strategic asset allocation among various asset classes. ACM will then construct a portfolio based on a tactical implementation of this portfolio allocation, taking into consideration asset class valuations and current market valuations. For certain Clients, ACM offers an investment management service that incorporates financial planning to create an initial baseline of the Client’s investment needs prior to implementing through a portfolio allocation. The Advisor bases its portfolios on its internal investment models, but may customize its portfolios based on the specific needs of each Client. Clients may impose reasonable restrictions on their accounts and legacy investments may be retained under certain circumstances, such as to avoid tax consequences upon a sale of such investments. In such instances, the Advisor will adjust the portfolio strategy to include the characteristics of these investments. The Advisor typically constructs portfolios utilizing diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds, options and other types of investments, as appropriate, to meet the needs of its Clients. Due to specific custodial and/or mutual fund company constraints, material tax consideration, and/or systematic investment plans, ACM will retain a mutual fund share class that does not have trading costs, but does have higher internal expense ratios than institutional share classes. ACM will seek to select the lowest cost share class available that is in the best interest of each Client and will ensure the selection aligns with the Client’s financial objectives and stated investment guidelines. ACM’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. ACM will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. ACM evaluates and selects investments for inclusion in Clients’ portfolios only after applying its internal due diligence process. ACM may recommend, on occasion, redistributing investment allocations to diversify the portfolio. ACM may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. ACM may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] Page 5 in the portfolio, change in risk tolerance of the Client, generating cash to meet the Client’s needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will ACM accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Clients assets will be managed within their designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. For additional information, please see Item 12 – Brokerage Practices. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue

Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Financial Planning Services ACM will typically provide a variety of financial planning services to Clients, either as a component of wealth management services or offered separately for Clients with less than $250,000 in assets under management, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to, investment planning, retirement planning, personal savings, tax planning, insurance planning, debt management, divorce planning, social security planning, education savings, second opinion reviews and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to, the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. ACM may also refer Clients to an accountant, attorney or another specialist, as appropriate, for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services ACM provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Page 6
• Vendor Analysis
• Investment Management Services (ERISA 3(38))
• Ongoing Investment Recommendation and Assistance These services are provided by ACM serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of ACM’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging ACM to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – ACM, in connection with the Client, will develop a strategy that seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – ACM will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk of each Client.
• Portfolio Construction – ACM will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – ACM will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs ACM does not manage or place Client assets into a wrap fee program. E. Assets Under Management As of December 31, 2023, ACM manages $84,131,507 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time.