Introduction Faithward Capital is a dba of SevenOneSeven Capital Management, LTD (“Faithward Capital”), a registered investment adviser based in Lancaster, Pennsylvania. SevenOneSeven is a limited liability company, organized under the laws of the Commonwealth of Pennsylvania. We have been providing investment advisory services since 2019. As of January 1, 2024, SevenOneSeven Holdings, owns 10% of SevenOneSeven Capital Management and Faithward Holdings, LLC owns 90%. Robert T. Nayden is the Managing Member of SevenOneSeven Holdings, LLC, and Adrian E. Young is the CEO of Faithward Holdings, LLC. You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to anyone from our firm who is an officer, employee, and all individuals providing investment advice on behalf of our firm. Where required, such persons are properly registered as investment adviser representatives. Faithward Capital (dba) offers advisory services as a sub-adviser to clients of other advisers, registered investment companies or portfolio model provider to investment advisers and other financial institutions. Portfolio Management Services Our firm offers continuous discretionary portfolio management services. Discretionary portfolio management means we will make investment decisions and place buy or sell orders in clients’ accounts without contacting clients for prior approval. These decisions are made based upon the client’s stated investment objectives and selected model portfolios and/or strategies. You may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. We will monitor portfolio performance on a continuous basis, and rebalance portfolios whenever necessary, as changes occur in market conditions, clients’ financial circumstances, or both. Portfolio Management Services Through Financial Intermediaries Faithward Capital (dba) maintains model portfolios and makes them available to various financial institutions, including other investment advisers, for their Separately Managed Accounts (“SMAs”). Separately Managed Accounts An SMA is a term within the financial services industry used to describe an individually managed account offered by a registered investment adviser. Such investment advisers offer clients access to a wide array of money managers like Faithward Capital (dba) from which the client can choose. When a client selects Faithward Capital (dba) through these programs, they will usually grant the firm trading discretion over the account. With this authority, Faithward Capital (dba) directs trading activity in the account according to its investment process and securities selection discipline. Each SMA requires its own custodial account. As a result, a client who chooses to invest with multiple managers may maintain multiple custodial accounts, one for each asset manager selected. The differences in trade executions, as well as investment restrictions

and fees that these types of programs impose can cause accounts with the same money manager and discipline to perform differently over the same time period. SMA accounts may be managed as part of a wrap fee program. Under wrap fee programs, the program sponsor manages client accounts for a single fee that includes portfolio management services, custodial services, and trade execution. Out of that fee, the program sponsor is responsible for paying a portion of the wrap fee as an investment advisory fee to Faithward Capital (dba). Sub-Advisory Services We offer sub-advisory services to various registered investment advisers to actively manage certain client assets under our investment programs. Under such arrangements, we offer research, analysis, and consultations to said registered investment advisers. In certain arrangements, we provide directed transaction orders on behalf of said registered investment advisers. Our portfolio management personnel communicate portfolio changes and general investment environment outlook through periodic reports and meetings. Where applicable, we may agree to conduct all trading, rebalancing, cash management and portfolio construction for certain said registered investment advisers clients’ accounts. Sub-Advisory Services for Registered Investment Companies Faithward Capital (dba) offers sub-advisory services to registered investment companies (“Funds”), including exchange traded funds (ETFs). Where we serve as a sub-adviser to registered investment companies ("Funds") and where appropriate, we will exercise our discretionary authority and without further approval from you, we will invest a percentage of your assets in such Funds. The fees we charge are separate and in addition to any fees and expenses charged by such Funds. You should refer to the prospectus for a complete description of the fees, investment objectives, risks and other relevant information associated with investing in such Funds. Refer to the Investment Discretion section below for additional disclosures on our discretionary authority to manage your investment account. Securities held in separate accounts may also be the same securities as those purchased by such Funds. The values of your holdings in such Funds are not included in the calculation of the advisory fee you pay to our firm. Except as otherwise required by law for ERISA assets, we do not offset any compensation we receive against fees and expenses you may otherwise pay to our firm, including any compensation we receive as an investment adviser to such Funds. Wrap Fee Programs Faithward Capital (dba) is not the sponsor or manager of a wrap fee program. However, our firm may act as a sub- adviser to wrap fee program accounts sponsored and/or directly managed by other investment advisers. Assets Under Management As of December 31, 2023, we had approximately $631,167,933 in discretionary assets under management and no assets under management on a non-discretionary basis.