A. Description of the Advisory Firm Kastel Capital Advisors, LLC (hereinafter “KCAL”) is a Limited Liability Company organized in the State of Massachusetts. The firm was formed in April 2015 and is owned by Drasko Kovrlija and Matthew V. Pierce. B. Types of Advisory Services Portfolio Assessment Services Includes a review of a prospective client’s existing portfolio. The review would center on cost, performance and suitability issues of the current portfolio and possible considerations for improvement. Investment Policy Statement Services Includes the creation of a comprehensive investment plan involving identification of a prospective client's goals, objectives, risk tolerance, investment horizon, and a strategic portfolio allocation as well as a tactical implementation plan. Financial Plan Services Includes the creation of a comprehensive financial plan tailored to a client’s situation, needs, and objectives. The services may include, but are not limited to: retirement, investment, estate, tax, and insurance/risk management planning. Unless explicitly excluded from scope, KCAL financial plans typically include an Investment Policy Statement. Wealth Management Services KCAL wealth management services consist of: a) Portfolio Management Services; and b) Financial Planning Services as defined below. Portfolio Management Services KCAL ongoing portfolio management services are based on the individual goals, objectives, time horizon, and risk tolerance of each client. KCAL creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring KCAL evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. KCAL will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. KCAL seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of KCAL’s economic, investment or other financial interests. To meet its fiduciary obligations, KCAL attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, KCAL’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is KCAL’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Financial Planning Services KCAL ongoing financial planning services are tailored to a specific client situation. The services may include, but are not limited to: retirement, estate, tax, and college planning. As part of this service, KCAL will typically create a financial plan for the client and update the plan on an on-going basis. Institutional Asset Management Services KCAL offers ongoing portfolio management services for institutions such as endowments, foundations, and pensions. KCAL works with the client organization to create the appropriate policy documents (investment, spending, etc.), then we create, implement, and manage the appropriate investment portfolio. Insurance Consulting KCAL has a relationship with DPL Financial Partners, LLC (“DPL”). By working with DPL, KCAL may provide insurance reviews/analyses, education, and insurance solutions in a manner that minimizes conflicts. DPL is a third-party provider of a platform of insurance consultancy services to SEC- registered investment advisers (“RIAs”) that have clients with a current or future need for insurance products. DPL offers RIAs memberships to its platform for a fixed annual fee and, through its licensed insurance

agents who are also registered representatives of The Leaders Group, Inc. (“The Leaders Group”), an unaffiliated SEC-registered broker-dealer and FINRA member, offers members a variety of services relating to fee-based insurance products. These services include, among others, providing members with analyses of their current methodology for evaluating client insurance needs, educating and acting as a resource to members regarding insurance products generally and specific insurance products owned by their clients or that their clients are considering purchasing, and providing members access to and product marketing support regarding fee-based products that insurers have agreed to offer to members’ clients through DPL’s platform. For providing platform services to RIAs, DPL receives service fees from the insurers that offer their fee-based products through the platform. These service fees are based on the insurance premiums received by the insurers. DPL is licensed as an insurance producer in Kentucky and other jurisdictions where required to perform the platform services. Its representatives are also licensed as insurance producers, appointed as insurance agents of the insurers offering their products through the platform, and registered representatives of The Leaders Group. Through DPL’s platform, KCAL may provide advice to a client on the investment options available in a client’s variable annuity. In this case, KCAL will charge an asset-based fee to the client and will include the value of the annuity contract in the client’s portfolio when determining KCAL’s advisory fee. KCAL charges no other fees to its clients related to the DPL platform. Services Limited to Specific Types of Investments KCAL generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds and non-U.S. securities. KCAL may use other securities as well to help diversify a portfolio when applicable. Fiduciary Disclosure When we provide investment advice to your regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions KCAL offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent KCAL from properly servicing the client account, or if the restrictions would require KCAL to deviate from its standard suite of services, KCAL reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. KCAL does not participate in any wrap fee programs. E. Assets Under Management KCAL has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $107,343,611 30,577,005 12/31/2023