A. Kingsbury Capital Investment Advisors Kingsbury Capital Investment Advisors, LLC ("KCIA,” and/or the “firm"), is an Illinois limited liability company and is registered with the SEC as an investment adviser. The firm is principally owned by William Vellon and Asher Wolmark and has been providing investment advisory and asset management services since 2008. B. Advisory Services Offered KCIA is an independent investment advisory and asset management firm offering a variety of financial services to individuals and high-net-worth individuals, trusts, retirement plans, pension and profit sharing plans, corporations, partnerships, and other legal entities. Advisory services may include investment strategy and portfolio management. KCIA receives a limited power of attorney to effect securities transactions on behalf of its clients that include securities and strategies itemized in Item 8 of this Brochure. In addition KCIA, pursuant to the terms of its investment advisory agreement with clients, has discretionary authority to determine which securities are to be bought and sold, the price of such securities, the executing broker and the commission rates to be paid to effect such transactions, as more fully described in Item 16 of this Brochure. We may also retain third-party money managers to manage a portion of the client's investment portfolio. Clients will be asked to complete a questionnaire establishing their financial situation, goals, needs, and tolerance for risk, and to factor in any additional personal or financial circumstances that they mandate. KCIA will then review the responses to the questionnaire and obtain any additional information, if necessary, and recommend a suitable portfolio of investments. Should the client agree, KCIA will implement the recommended portfolio. In lieu of the unique nature of trusts, corporate or institutional plans, funds or otherwise for which KCIA provides services, the client and firm will establish goals under the direction of one or more trustees or the authorized executive of the plan or trust, which will be part of the Investment Policy Statement. Such information will include goals, needs, and tolerance for risk, and to factor in any additional restriction, requirement of the trust(s) and beneficiaries as they respect to the plan, trust or fund, or financial circumstances that they mandate. Clients have the right to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio (to be noted on the client agreement), and should promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. KCIA will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. KCIA will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. Institutional Retirement Investment Advisory Services Employees in qualified retirement plans are protected by the Employee Retirement Income Security Act of 1974 (ERISA), which requires employers, investment advisors, and plan administrators to put employees’ interests first when managing retirement savings plans. Public retirement systems are governed by similar state laws and often incorporate the protections of ERISA. In order to demonstrate that a plan fiduciary has operated in a prudent manner, there are certain steps that the fiduciary must take. KCIA is committed to helping fiduciaries understand their roles and to assist them in implementing a process that allows them to fulfill their duties and responsibilities. KCIA offers government retirement systems, sponsors of employee benefit plans (defined contribution and defined benefit) qualified under the Internal Revenue Code (“IRC”), and other retirement plans not qualified under the IRC (including Taft-Hartley organizations and “church” plans) a range of discretionary and non-discretionary services, including the selection of registered investment companies or other pooled investment funds to be offered under the plan. KCIA will assist plan fiduciaries in the following areas: ▪ Investment Selection and Monitoring
• Creating an investment policy statement
• Modeling asset allocations
• Selecting investment managers
• Monitoring the investment options against well-defined risk and return criteria
• Monitoring costs, fees and other criteria that relate to Plan Sponsor oversight responsibilities ▪ Plan Evaluation/Benchmarking KCIA also “benchmarks” retirement plans against those of organizations in the same industry and against national normative data. Factors that KCIA evaluates include the following:
• Participation, deferral percentage, and asset allocation
• Investment performance
• Plan design
• Total plan costs
• Compliance
• Participant education and communication
• Recordkeeping and administration
• Technology
• Service provider capabilities and profiles KCIA investment professionals work in partnership with clients to create sound solutions to investment challenges, including:
• Maximizing long-term return while not assuming unnecessary risk
• Creating an optimal portfolio that includes a diverse array of investment options that span the risk/return spectrum
• Keeping plan sponsors current on manager performance and the events that may affect performance ▪ Vendor Search and Selection and Plan Implementation KCIA also assists its retirement plan clients in selecting trustees, custodians, accountants, actuaries, and other service providers. This process involves:
• Generating criteria to identify appropriate service provides
• Developing requests for proposals
• Objectively rating service providers
• Evaluating highly rated service provider candidates Once a service provider is selected, KCIA will assist a client in implementing the client’s retirement plan program. In implementing the program, KCIA will, among other things, review the plan design, develop performance standards, and review the service provider’s contract. ▪ Ongoing Plan Operations Support KCIA also provides assistance with strategic employee education and communications in connection with client retirement plan programs, as well as ongoing plan sponsor administrative support with respect to the Plan. We will assist in designing appropriate participant education strategies, provide on-site education and enrollment meetings, and provide supporting education and counseling specific to participant benefits under the plan. As retirement program administration is central to the successful operation of the plan, we will provide support to Plan Fiduciaries in fulfilling their obligations through guidance with respect to compliance with rules and regulations as they apply to each specific situation. KCIA will not provide legal advice as we are not licensed attorneys; however, we can provide guidance based on our expertise as well as client resources specific to benefit plan operations and general employee benefit issues. KCIA, in conjunction with Service Provider recommendations, will provide ongoing management and support of vendor transitions, such as a change in recordkeeper, investment managers, or other providers. Limitations with Regard to KCIA Services and Plan Establishment, Termination or Other Employer Needs In no event will the services of KCIA specific to a Plan for which we receive payment out of plan assets be related solely to the Plan Sponsor. Our obligation as fiduciaries prohibits receiving any compensation from plan assets unless solely related to plan operations as defined under ERISA. In some cases clients may enter separate agreements with other professionals (who may also be KCIA Investment Advisor Representatives) with specific expertise in benefit plan management. Limitations with Regard to Participant Education and Investment Advice KCIA does not provide individual advice to plan participants as part of the services to the Plan. Individual participants

may or may not engage KCIA for personalized financial advice for their personal investment needs. KCIA and/or plan vendors may make available individual, personal investment advice services, including automated advice modules, asset allocation services or other means to deliver individual advice through other parties, and fees to the participant or the plan may apply. In no event will Kingsbury have any relationship or arrangement which results in KCIA having an economic interest or benefit from such arrangements. KCIA will provide ongoing support in the evaluation of the individual advice vendor, as appropriate. Limitation of Services with Respect to Participant Directed Employer Plans, Annuities, or Other Arrangements In some cases KCIA will act as an advisor to a Plan, Trust or Employer with respect to investments held on behalf of participants of a plan established by the Employer. KCIA in its role may or may not make available other services that provide advice to participants, unless directed by the Plan that is deemed “investment advice” under ERISA. KCIA, in its unique role with respect to plan assets, or assets held in a trust, annuity or other arrangement, may be in position to advise or make recommendations of a personal nature. KCIA will take into account the specific information unique to the participant in executing its obligations as required by the terms of agreement, or as requested by a participant if applicable. Participants, in their sole discretion, may enter into separate agreements for other services with our firm with respect to other personal assets. Any advice provided to a natural person who is a beneficiary of the plan or trust that is incidental to the providing of services to the plan or trust will be based on the objectives, restrictions or otherwise established with the client on behalf of participants or beneficiaries as necessary, and take into account personal information provided by the participant. Any arrangement to provide “advice” as defined under ERISA on behalf of plan participants that is established by the employer or plan sponsor is intended to meet applicable regulations. KCIA and Client agree to modify such arrangement, and make available information with regard to administration, certification or any required changes, restrictions, or circumstances effecting such arrangement as needed. Such advice, if provided to participants, will be at the discretion of the participant, and will be limited to the specific information disclosed by the participant and any information provided in the context of participation in a plan or status as an employee or independent contractor of an employer. In many cases, such systems, tools, programs that are used to provide these services will be under a separate arrangement with one or more service providers to a plan or trust. KCIA and Client may also enter into agreements limited nature with respect to Participant Advice, or other services of a personal nature specific to a beneficiary of a plan or trust. Such agreements may be provided through or on behalf of a plan, a plan service provider, trust company, bank or insurance company qualified to perform services required by the Client, or any combination of the above. KCIA services are limited in nature with respect to Employer Plans, in that KCIA, as investment advisor, does not act as, or substitute for, the Plan Sponsor, with respect to other service providers to the Plan or Trust. KCIA may make recommendations that include other services in addition to investments or investment related services on behalf of plans. Client agrees to notify KCIA of any change to, or restrictions of, its objectives and obligations under the Plan as needed. KCIA, in its role, may also provide advice and guidance with regard to such services. KCIA, in its role, does not have any interest in such service providers, and does not benefit from any recommendation unless specifically authorized by a plan. Financial Planning Services Clients will receive a written or oral report (depending on the client’s preference) providing a basic financial plan designed to help achieve their stated financial goals and objectives. Based on the client’s needs, financial planning services may include (but are not limited to) the following: ▪ Preparation of a recommended asset allocation that serves to diversify the client's portfolio among different categories of investments, such as domestic and international small, medium, and large capitalization securities; corporate and government fixed income (short-, intermediate-, and long-term maturities); emerging market securities (i.e., foreign issuers); real estate investment trusts; and such other alternative asset categories that are suitable in light of the client's investment goals, objectives, and risk tolerance. ▪ Preparation of an investment policy statement setting forth the client’s investment plan, with specific direction in terms of diversification requirements, tax issues, estate planning issues, risk tolerance, retirement, and other identified objectives of the client, including a targeted rate-of-return objective. ▪ Preparation of a retirement plan that serves to identify whether the client is saving enough and investing in a way that meets retirement objectives in light of the client's financial circumstances and risk tolerance. ▪ Preparation of cash flow projections to ensure that the client can meet daily living expenses and obligations. ▪ Insurance planning to meet the needs of the client, taking into account family, business, and other financial objectives of the client. ▪ General family office and business consulting:
• Retirement objectives
• Philanthropy
• Estate planning
• Wealth transition
• Business succession and related issues
• Recommendation of third-party managers for use by the client KCIA gathers required information through in-depth personal interviews and questionnaires. Information gathered includes a client's current financial status, investment objectives, future goals, and attitudes toward risk. Related documents supplied by the client are carefully reviewed, and a report is prepared covering one or more of the above-mentioned topics as directed by the client. Account Aggregation Services KCIA, subject to client authorization, provides account aggregation services to its clients. KCIA through a third-party service provider will provide a secure website that aggregates various investment accounts from various financial institutions so clients can view their investment holdings in one place. Certain financial institutions may not support this service. If any of your accounts are not able to link with our service, KCIA will submit a request to have them added, but cannot guarantee that all links will be successful. Account Aggregation Services for Trusts, Retirement Plans, Insurance through Outside Firms KCIA, subject to client authorization, may utilize, provide or have access to outside account aggregation services on behalf of clients. KCIA through a third-party service provider will provide a secure website that aggregates various investment accounts from various financial institutions so clients, which may include corporate retirement plans, trusts, or other funds, can manage their obligations under any such plan, trust or fund. For plans, such services may include participant access and related services. Certain financial institutions may not support this service, and the Client is required to provide sufficient information, restrictions, or directives to KCIA, so that the firm may recommend a suitable portfolio of investments. C. Client-Tailored Services and Client-Imposed Restrictions Clients’ accounts will be managed on the basis of their financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs KCIA does not participate in wrap fee programs. (Wrap fee programs offer services for one all- inclusive fee.) E. Client Assets Under Management As of December 31, 2023, KCIA had $121,252,310 in discretionary and $14,893,556 in non- discretionary client assets under supervision.