This Disclosure document is being offered to you by Investment Management Associates, Inc. (“IMA” or “Firm”) about the investment advisory services we provide. It discloses information about our services and the way those services are made available to you, the client. Our Firm was formed in 1979. The principal owner is Vitaliy N. Katsenelson. We are committed to helping clients build, manage, and preserve their wealth, and to provide guidance that helps clients to achieve their stated financial goals. We specialize in retirement investing and income generation. We will offer an initial complimentary meeting upon our discretion; however, investment advisory services are initiated only after you and IMA execute an Investment Management Agreement. Investment Management Services We provide ongoing discretionary investment management services to clients. We offer non-discretionary investment management upon request by the client. Once we determine a client’s profile, income need, and investment plan, we execute the day-to- day transactions. On an exceptional basis only, when we do not have access to an account to execute trades, we will provide trade recommendations to the client and the client will be responsible for choosing to execute. Ongoing account supervision is guided by the client’s written profile and investment plan. We may accept accounts with certain restrictions if circumstances warrant. We primarily allocate client assets among various equities, options, and debt securities. In personal discussions with clients, we determine their date and dollar specific objectives, time horizons, risk tolerance and liquidity and income needs. As appropriate, we also review their prior investment history, as well as family composition and background. We create and manage the client’s investments based on their plan pursuant to achieving

their goals. It is the client’s obligation to notify us immediately if circumstances have changed with respect to their goals and income needs. Once we have determined the appropriate strategy for clients or client businesses and executed the strategy, we will provide ongoing investment review and management services. With our discretionary relationships, we will make changes to the portfolio, as we deem appropriate. We change portfolios when our client’s goals change. We tailor our advisory services to meet the needs of our clients and seek to ensure that your portfolio is managed in a manner consistent with those needs and objectives. You will have the ability to leave standing instructions with us to refrain from investing in particular industries or invest in limited amounts of securities. You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks exist that adversely affect an account’s performance. This could result in capital losses in your account. If a non-discretionary relationship is in place, calls will be placed to the client presenting the recommendation made including a rebalancing recommendation and only upon your authorization will any action be taken on your behalf. Our clients should note that being in a discretionary or non-discretionary account does not affect the management of the accounts. It is the decision of the client on what type of account they elect to open with our firm – a discretionary account without prior notification of investment trades or a non-discretionary account as described above. Wrap Fee Programs We do not participate in Wrap Fee programs. Assets As of February 29, 2024, IMA managed $480,906,139 on a discretionary basis and $34,476,454 on a non-discretionary basis.