Tannin Capital offers a variety of services, which include financial planning, consulting, and investment management services Prior to Tannin Capital rendering any of the foregoing services, clients are required to enter into one or more written agreements with Tannin Capital setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Tannin Capital is wholly owned by Clay Young. The Firm has conducted business as an investment adviser since April 2017. The Firm filed for registration with the SEC as a large investment adviser in October 2021. Tannin Capital had approximately $362,317,175 in regulatory assets under management as of December 31, 2023, approximately $267,169,236 of which was managed on a discretionary basis and $95,147,939 of which was managed on a non-discretionary basis. While this brochure generally describes the business of Tannin Capital, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on Tannin Capital’s behalf and is subject to the Firm’s supervision or control. Financial Planning and Consulting Services Tannin Capital offers clients a broad range of financial planning and consulting services, which includes any or all of the following functions:
• Business Planning
• Cash Flow Planning
• Trust and Estate Planning
• Insurance Planning
• Retirement Planning
• Education Planning
• Tax Planning These services are rendered in conjunction with investment management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, Tannin Capital is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. There is a conflict of interest where Tannin Capital recommends clients engage the Firm for additional related services, including management of additional assets and implementation of its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Tannin Capital or its affiliates to provide (or continue to provide) additional services for compensation, including, without limitation, investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Tannin Capital under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm

of any change in their financial Page | 5 © MarketCounsel 2024 situation or investment objectives for the purpose of reviewing, evaluating or revising Tannin Capital’s recommendations and/or services. Investment and Wealth Management Services Tannin Capital manages client investment portfolios on a discretionary or non-discretionary basis. In addition, Tannin Capital provides certain clients with wealth management services which includes a broad range of comprehensive financial planning and consulting services as well as discretionary and/or non- discretionary management of investment portfolios. Tannin Capital primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, options and loans (pooled and individual through government programs) in accordance with their stated investment objectives and dependent upon the representative working with the client. Portfolios will be balanced utilizing many of the instruments mentioned or using fixed-income instruments only. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, however, clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage Tannin Capital to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Tannin Capital directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. Tannin Capital tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Tannin Capital consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Tannin Capital if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if Tannin Capital determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts.