EM 4 Who We Are Xcel Wealth Management, LLC (hereinafter referred to as “Xcel”, the “Company” “we”, “us” and “our”) is a registered investment advisor1 organized in August 2011 as a Florida Limited Liability Company to assist you, our client2, achieve superior investment returns in your investment portfolio.3 Owners The following person controls Xcel: Name Title CRD# Jonathan S. Xynidis Managing Member & Chief Compliance Officer 4174055 Assets Under Management As of December 31, 2022, our assets under management totaled: Client Discretionary Managed Accounts ......................... $348,439,884 Client Non-Discretionary Managed Accounts ................... $12,536,625 Our Mission Our mission is to manage your investable assets and to assist you in making intelligent, informed decisions on how best to achieve long-term growth and capital appreciation in your investment portfolio. We maintain one overall objective – structure and implement investment strategies designed to maximize wealth, maintain investment expectation, and minimize risk. What We Do We manage wealth. Our portfolio management services begin with stressing the importance of you making fiscally responsible decisions and disciplined economic choices in your personal life so we can effectively help you achieve your monetary goals for today’s needs, tomorrow’s dreams, and a future legacy. Focus of our portfolio management will be to identify your unique investment parameters that once defined, will allow us to provide clear perspective and insight into the investment alternatives to be most effective for your situation. These identifying parameters are a beginning point to successful portfolio management that includes: 1 The term “registered investment advisor” is not intended to imply that Xcel Wealth Management, LLC has attained a certain level of skill or training. It is used strictly to reference the fact that we are “registered” as a licensed “investment advisor” with the United States Securities & Exchange Commission (the ”SEC”) – and “Notice Filed” with State Regulatory Agencies that may have limited regulatory jurisdiction over our business practices. 2 A client could be a high net-worth individual and their family members, a family office, a foundation or endowment, a charitable organization, a corporation and/or small business, a trust, a guardianship, an estate, or any other type of entity to which we choose to give investment advice. 3 Xcel Wealth Management, LLC is a fiduciary, as defined within the meaning of Title I of the Employer Retirement Income Security Act of 1974 (“ERISA”) and/or as defined under the Internal Revenue Code of 1986 (the “Code”) for any investment services provided to a client who is: (i) a plan participant or beneficiary of a retirement plan subject to ERISA or as described under the Code; or (ii) the beneficial owner of an Individual Retirement Account (“IRA”). v Risk Assessment – An attempt to identify your level of tolerable risk to an acceptable level of market volatility and expected investment return. v Investment Composition – An investment strategy designed to achieve your unique financial expectations relative to your risk factors and predetermined benchmarks. v Tax Management – Income producing investments, if at or nearing retirement or are risk averse, designed to protect assets and capitalize on investment returns that yield either a low tax base income or are tax exempt. From these identifying factors we will construct managed portfolios consist primarily of equity (“stock”) positions, fixed income/debt (“bond”) instruments, derivatives (“options”) contracts, investment company (“mutual fund”) products, and exchange traded funds (“ETFs”). You can find more information about our management fees and services under “Portfolio Management” in Item 5, “Fees & Compensation” and further description of our management style under Item 8, “Methods of Analysis, Investment Strategies & Risk of Loss”. How We Get to Know You As a new client, we will have a pre-advisory consultation with you to discuss issues such as your current income and expenses, career, personal goals, investment return expectations and prior investment experience. In addition, we may have you complete a profile questionnaire4 to gain greater insight into your financial needs. With the complexity of today’s marketplace, it is critical for us to understand who you are and what you want to accomplish financially. We must have a clear picture of your unique financial composition and risk tolerance so that we can develop a successful portfolio management strategy and tailored asset allocation guideline. Our meetings with you to discuss your finances will help to eliminate much of the guesswork in achieving the security and independence you desire and simplify your financial alternatives. In return, we will have: v Defined and narrowed objectives and investment options; v Identified areas of greatest distress; v Developed a strategy for addressing concerns about the future; v Cultivated peace of mind; and, v Created a unique picture of your overall economic personality. Once your financial parameters have been identified, we will prepare an asset allocation plan that outlines what asset mix is most suitable for your unique investment expectations and risk tolerance. This asset allocation plan will guide us in the management of your account(s), and as a standard against which to measure future results and to make modifications where necessary. 4 The profile questionnaire we use is an important tool in gathering information about your investment methodology, risk tolerance, income/tax bracket, liquidity, time horizons, etc. If you elect not to answer the questionnaire

or chooses to respond with limited input, it is possible that we could operate in a handicapped capacity contrary to your investment needs. Therefore, if you desire the most effective and accurate recommendations regarding your managed account(s), you should make every effort to provide us with your detailed personal needs and objectives, along with detailed financial and tax information. FEES & COMPENSATION 5 Portfolio Management Portfolio management is provided on an asset-based fee arrangement. Management fees are calculated based on the aggregate market value of your account on the last business day of the previous calendar quarter multiplied by one-fourth of the corresponding annual percentage rate for each portion of your portfolio assets that fall within each tier (See “Billing” below under “Protocols for Portfolio Management” for more information.). We retain discretion to negotiate the management fee within each tier on a client-by-client basis depending on the size and complexity of the portfolio managed. In addition, a fee break will occur as assets in your portfolio increase past the following tier: Account Value Annual Fee Rate Not to Exceed First $2,000,000 ............................................... 1.50% Over $2,000,000 .............................................. 0.75% We do not require a minimum initial investment to open a managed account; however, we retain the option to accept your request for us to manage your Portfolio regardless of the account size. Protocols for Portfolio Management The following protocols establish how we handle our portfolio management accounts and what you should expect when it comes to: (i) managing your account; (ii) your bill for investment services; and (iii) other fees charged to your account(s). Discretion Over than for certain retirement plans, we will establish discretionary trading authority on all management accounts to execute securities transactions at any time without your prior consent or advice. You may, however, impose restrictions, in writing, on our discretionary authority (i.e., limit the types/amounts of particular securities purchased for your account, exclude the ability to purchase securities with an inverse relationship to the market, limit our use of leverage, etc.). Billing Your account will be billed a blended fee quarterly in arrears based on the fair market value for the portion of your portfolio that fall within each tier of our fee schedule. For example: Account Value: $5,000,000 Annual Fee % (Per Tier) Tier Fee Contribution (Based on the Account Value Within Each Tier) First $2,000,000 1.50% 0.60% Next $3,000,000 0.75% 0.45% Blended Annual Fee % 1.05% For new managed accounts opened in mid-quarter, our fee will be based upon a pro-rated calculation of your assets managed for the prior quarterly period. Advisory fees will be deducted first from any money market funds or cash balances. If such assets are insufficient to satisfy payment of such fees, a portion of the account assets will be liquidated to cover the fees. Fee Exclusions The above fees for all of our management services are exclusive of any charges imposed by the custodial firm including, but not limited to: (i) any Exchange/SEC fees; (ii) certain transfer taxes; (iii) service or account charges, including, postage/handling fees, electronic fund and wire transfer fees, auction fees, debit balances, margin interest, certain odd-lot differentials and mutual fund short-term redemption fees; and (iv) brokerage and execution costs associated with securities held in your managed account. There can also be other fees charged to your account that are unaffiliated with our management services. In addition, all fees paid to us for portfolio management services are separate from any fees and expenses charged on mutual fund shares by the investment company or by the investment advisor managing the mutual fund portfolios. These expenses generally include management fees and various fund expense, such as: redemption fees, account fees, and purchase fees may occur but are the exception within managed accounts at institutional custodians. A complete explanation of these expenses charged by the mutual funds is contained in each mutual fund’s prospectus. You are encouraged to carefully read the fund prospectus. Termination of Investment Services To terminate investment advisory services, either party (you or us) by written notification to the other party, may terminate the Investment Advisory Agreement at any time, provided such written notification is received at least 30 days prior to the date of termination. Such notification should include the date the termination will go into effect along with any final instructions on the account (i.e., liquidate the account, finalize all transactions and/or cease all investment activity). In the event termination does not fall on the last day of a calendar quarter, we will bill your account a pro-rated quarterly management fee based upon the number of days in the quarter we managed your portfolio. Once the termination of investment advisory services has been implemented, neither party has any obligation to the other – we no longer earn management fees or give investment advice and you become responsible for making all future investment decisions. PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT IT EM 6 We do not charge fees based on a share of capital gains or the capital appreciation of the assets held in your accounts.