A. OWNERSHIP/ADVISORY HISTORY Solomon API LLC (“we”) is registered as an investment adviser with the U.S. Securities and Exchange Commission (SEC). In 2012, we registered as a Florida and Texas registered investment adviser. Our original corporate structure was a Texas limited partnership. Due to growth, we became registered as an investment adviser with the U.S. Securities and Exchange Commission in 2019. In June 2023, we reorganized from the Texas limited partnership to a Florida limited liability company. Our managing members are Matthew Myland (“Mr. Myland”) and Paul Stanley (“Mr. Stanley”). Mr. Stanley is also the firm’s Compliance Officer. Additional information about Mr. Myland and Mr. Stanley can be found in their supplemental brochures – ADV Part 2B. B. ADVISORY SERVICES OFFERED i. FINANCIAL PLANNING SERVICES Financial Planning services typically focus on one or more specific areas such as financial and cash management, risk management, financial issues relating to divorce or death of a family member, insurance planning, estate planning, tax issues, retirement planning, educational funding, goal setting, or other needs identified by the client or by our review of the client’s financial circumstances. Through discussion with the client and/or questionnaires, we will collect pertinent data, identify goals, objectives, financial concerns and potential solutions. We will present the client with a written analysis. Following the conclusion of the financial planning services, we may make recommendations regarding implementation of the financial strategies discussed. Clients always have the right to choose whether to follow and through whom to implement the recommendation. ii. PORTFOLIO MANAGEMENT SERVICES We manage individualized portfolios for our clients. We work with each client to formulate an individualized portfolio based upon his/her objectives, time frame, risk parameters and other investment considerations. We use a variety of securities that may include, among other securities, bonds, common stock (equities), options (limited to covered calls and puts for limited positions only), exchange traded funds,

exchange listed real estate investment trusts, mutual funds and treasury bonds. (Additional information about securities used and their risks can be found under Item 8.) Our investment philosophy is to use principals of value, safety and quality to seek investment options globally. We place heavy emphasis on risk control, believing that avoiding losses allows appreciation potential of equities to be realized. Our services are offered on a discretionary and non-discretionary basis. Please see Item 16 for additional details. i. PARTICIPANT ACCOUNT MANAGEMENT We use a third-party platform to facilitate the management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of client funds because we do not have direct access to client log-in credentials when we affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the client allowing him or her to connect an account(s) to the platform. Once the client account(s) is connected to the platform, we will review the current account allocations. When deemed necessary, we will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account Solomon API Page 5 ADV Part 2A – 3/22/2024 performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least annually, and allocation changes will be made as deemed necessary. C. TAILORED SERVICES We generally do not allow clients to impose restrictions on the management of their accounts i.e., to avoid certain asset classes or industries. However, we may allow restrictions at our discretion. D. WRAP PROGRAM We do not sponsor or participate in a wrap program. E. CLIENT ASSETS MANAGED As of February 28, 2024, we manage approximately $280,000,000 in client assets on a discretionary basis.