Robbins Farley has been in business as an independently registered investment adviser since March 2017. However, the Firm’s principals have been in business operating under Robbins Farley since 2012. Colleen Farley and Robert Robbins are the Firm’s principals. Robbins Farley provides wealth planning and management services as well as corporate services. Robbins Farley does not limit the types of clients with whom it works, but most clients are individuals, their affiliated trusts, charitable organizations and businesses. Wealth Planning and Accumulation Financial Planning Robbins Farley’s focus is on assisting clients as they prepare for and ultimately experience the major transitions in their lives. For many clients, the only life transition that merits preparation is retirement. However, Robbins Farley believes that not only are there other major transitions but preparing for those as well can assist clients in their planning for retirement. Examples of transitions include marriage, divorce, death of a spouse, receipt of an inheritance, career changes, sale of a business. The first step in working with Robbins Farley is to gather information about the client, their goals and their current circumstances. Robbins Farley will request clients to provide documents regarding their income, tax status, savings, and investments, among other requests. Clients will engage with Robbins Farley in conversations where the client learns about Robbins Farley’s thought process and methods, and Robbins Farley gathers information needed to develop a proposed plan for moving forward. After this initial meeting, the Firm will review, research, and prepare a proposal for the client. This proposal is presented at a separate meeting, where the client reviews the proposal and considers whether to engage the Firm to continue its work. Ultimately this proposal forms the map from which both the client and Robbins Farley take direction throughout the engagement. Asset Management When we perform asset management services, we prefer to do so on a discretionary basis. This means that while we will continue an ongoing relationship with each client, being involved in various stages of their lives and decisions to be made, we will not seek specific approval of changes to the securities in client accounts. Clients can always make deposits or withdrawals in their accounts at any time. Because we take discretion when managing accounts, clients engaging us will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) as well as an agreement that outlines the responsibilities of both the client and Robbins Farley. Advisory services are tailored to the specific needs of an individual client. Clients may place reasonable restrictions on the management of assets, including specific securities or types of securities. However, clients should understand that significant restrictions cannot only decrease the ability of Robbins Farley to meet the client’s goals, but also increase the costs associated with managing the client’s portfolio. In very limited cases, Robbins Farley provides investment management services on a non-discretionary basis, which means we will consult with the client prior to implementing any investment recommendation. Clients should be aware that some recommendations may be time-sensitive, and, as such, their performance may or may not be affected if Robbins Farley is unable to reach them on a timely basis. Each client’s portfolio will be invested according to that client’s investment objectives. Robbins Farley determines these objectives with the client through reviewing client provided documents, client interviews and/or asking the client to put these objectives in writing. Once we ascertain your objectives for each account, we will develop a portfolio we believe will best fit your needs. This means allocating assets to one or more of our investment programs. The investment programs are not investment products. Clients may have different needs than others within the same investment program. Accordingly, not all clients in each investment program will have the exact same percentages of each underlying investment. The investment portfolios that we recommend are based on the needs of the client as compared with the typical behavior of that security type or manager, current market conditions, the client’s current financial situation (including assets that may be managed by another advisor), financial goals, and the timeline to meet those goals. Because we develop an investment strategy based on your personal situation and financial goals, your asset allocation guidelines may be similar to or different from another client. Asset Management – Institutional Intelligent Portfolios™ Program For some accounts, we provide portfolio management services through an investment service called Institutional Intelligent Portfolios™, an automated, online investment management platform for use by independent investment advisors offered by software provider Schwab Performance Technologies (the “Program” and “SPT,” respectively). Through the Program, we offer clients a range of investment strategies we have constructed and manage. The client’s portfolio is held in a brokerage account opened by the client at SPT’s affiliate, Charles Schwab & Co., Inc. (“CS&Co”). We are independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co or their affiliates (together, “Schwab”). We, and not Schwab, are the client’s investment advisor and primary point of contact with respect to the Program. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. We have contracted with SPT to provide us with the technology platform and related trading and account management services for the Program. This platform enables us to make the Program available to clients online and includes a system that automates certain key parts of our investment process (the “System”). The System includes an online questionnaire that helps us determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that when they use the online system to open an account, the system recommends a portfolio in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, if the adviser opens the account on the client’s behalf, the adviser selects the portfolio without the use of the online questionnaire. Rather, they base their portfolio selection on information that was gathered during data gathering discussions with the client. In either case, we make the final decision and select a portfolio based on all the information we have about the client. The System also includes an automated investment engine through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). We do not receive a portion of a wrap fee for our services to clients through the Program. Clients do not pay fees to SPT in connection with the Program, but we charge clients a fee for our services as described below under Item 5. Our fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co as part of the Program. Schwab does receive other revenues in connection with the Program, which are described in the “Compensation to Schwab Under the Program” section below. We do not pay SPT fees for the Platform. Clients enrolled in the Program are limited in the universe of investment options available to them. For example, the investment options available are generally limited to ETFs, whereas Robbins Farley recommends various other types of securities in its other services. The Program is designed to provide guidance and professional assistance to individuals who are beginning the process of accumulating wealth. Clients will have access to their accounts and a financial interface online but will also have the opportunity to confer with Robbins Farley with respect to their account. Rebalancing The System will rebalance a client’s account periodically by generating instructions to CS&Co. to buy and sell shares of funds and depositing or withdrawing funds through the “Sweep Program”, considering the asset allocation for the client’s investment strategy. Rebalancing trade instructions can be generated by the System when (i) the percentage allocation of an asset class varies by a set parameter established by Robbins Farley, (ii) Robbins Farley decides to change asset allocation percentages for an investment strategy or (iii) Robbins Farley decides to change a client’s investment strategy, which could occur, for example, when a client makes changes to their investment profile or imposes or modifies restrictions on the management of their account. Sweep Program Each investment strategy involves a cash allocation (“Cash Allocation”) that will be held in a sweep program at Charles Schwab Bank (the “Sweep Program”). The Cash Allocation will be a minimum of 4% of an account’s value to be held in cash, and may be higher, depending on the investment strategy chosen for a client. The Cash Allocation will be accomplished through enrollment in the Sweep Program, a program sponsored by CS&Co. By enrolling in the Program, clients consent to having the free credit balances in their brokerage accounts at CS&Co. swept into deposit accounts (“Deposit Accounts”) at Charles Schwab Bank (“Schwab Bank”) through the Sweep Program. Schwab Bank is an FDIC-insured depository institution that is a Schwab affiliate. The Sweep Program is a required feature of the Program. If the Deposit Account balances exceed the Cash Allocation for a client’s investment strategy, the excess over the rebalancing parameter will be used to purchase securities as part of rebalancing. If clients request cash withdrawals from their accounts, this likely will require the sale of fund positions in their accounts to bring their Cash Allocation in line with the target allocation for their chosen investment strategy. If those clients have taxable accounts, those sales may generate capital gains (or losses) for tax purposes. In accordance with an agreement with CS&Co., Schwab Bank has agreed to pay an interest rate to depositors participating in the Sweep Program that will be determined by reference to an index. Compensation to Schwab Under the Program Clients do not pay fees to SPT or brokerage commissions or other fees to CS&Co. as part of the Program. Schwab does receive other revenues, including (i) the profit earned by Charles Schwab Bank, a Schwab affiliate, on the allocation to the Schwab Intelligent Portfolios Sweep Program described in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/or administrative service fees (or unitary fees) received by Charles Schwab Investment Management, Inc., a Schwab affiliate, from Schwab ETFs™ Schwab Funds® and Laudus Funds® that Robbins Farley may select to buy and hold in the client’s brokerage account; (iii) fees received by Schwab from third-party ETFs that participate in the Schwab ETF OneSource™ program and mutual funds in the Schwab Mutual Fund Marketplace® (including certain Schwab Funds and Laudus Funds) in the client’s brokerage account for services Schwab provides; and (iv) remuneration Schwab may receive from the market centers where it routes ETF trade orders for execution. Important Disclosures Limitations of Financial Planning Services As

indicated above, to the extent requested by a client, Robbins Farley may provide financial planning and related consulting services. Neither Robbins Farley nor its investment adviser representatives assist clients with the implementation of any financial plan, unless they have agreed to do so in writing. Robbins Farley does not continuously monitor a client’s financial plan unless engaged to do so, and it is the client’s responsibility to revisit the financial plan with the Robbins Farley, if desired. Furthermore, although Robbins Farley may provide recommendations regarding non-investment related matters, such as estate planning, tax planning and insurance, Robbins Farley does not serve as a law firm or accounting firm, and no portion of Robbins Farley’s services should be construed as legal or accounting services. Accordingly, Robbins Farley does not prepare estate planning documents or tax returns. To the extent requested by a client, we may recommend the services of other professionals for non- investment implementation purpose (i.e., attorneys, accountants, insurance, etc.), including Robbins Farley’s affiliate, Robbins Farley Insurance, LLC (“RFI”), in its separate capacity as a licensed insurance agency-see Item 10 below. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Robbins Farley and/or its representatives. If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged unaffiliated licensed professional (i.e., attorney, accountant, insurance agent, etc.), and not Robbins Farley, shall be responsible for the quality and competency of the services provided. Conflict of Interest: The recommendation by a Robbins Farley representative that a client purchase an insurance product from RFI presents a conflict of interest, as the receipt of an insurance commission by RFI may provide an incentive to recommend insurance products based on commissions to be received, rather than on a particular client’s need. No client is under any obligation to purchase any securities or insurance commission products from RFI. Clients can purchase insurance products recommended by a Robbins Farley representative through other, non-affiliated insurance agencies. Retirement Rollovers - Potential for Conflict of Interest A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Robbins Farley recommends that a client roll over their retirement plan assets into an account to be managed by Robbins Farley, such a recommendation creates a conflict of interest if Robbins Farley will earn new (or increase its current) compensation as a result of the rollover. If Robbins Farley provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Robbins Farley is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets to an account managed by Robbins Farley, whether it is from an employer’s plan or an existing IRA. Account Aggregation Robbins Farley may provide periodic aggregated reporting services, which can incorporate all of the client’s investment assets including those investment assets that are not part of the assets managed by Robbins Farley (the “Excluded Assets”). Our service relative to the Excluded Assets is limited to reporting services only, which does not include investment implementation. Because we do not have trading authority for the Excluded Assets, to the extent applicable to the nature of the Excluded Assets (assets over which the client maintains trading authority vs. trading authority designated to another investment professional), the client (and/or the other investment professional) shall be exclusively responsible for directly implementing any recommendations relative to the Excluded Assets. The client and/or their other advisors that maintain trading authority, and not Robbins Farley, shall be exclusively responsible for the investment performance of the Excluded Assets. Without limiting the above, Robbins Farley shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that Robbins Farley provide investment management services (whereby we would have trading authority) with respect to the Excluded Assets, the client may engage us to do so pursuant to the terms and conditions of an advisory agreement. Portfolio Activity Robbins Farley has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Robbins Farley will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions or withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Robbins Farley determines that changes to a client’s portfolio are neither necessary nor prudent. Robbins Farley’s advisory fee referenced at Item 5 below remains payable during periods of account inactivity. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Use of Mutual and Exchange Traded Funds Robbins Farley may purchase mutual funds or exchange traded funds for a client’s account. Mutual funds and exchange traded funds impose fees at the fund level (e.g., management fees and other fund expenses) that are in addition to Robbins Farley’s investment advisory fee, and, to the extent applicable, the transaction fee charged by your custodian. Trustee Directed Plans Robbins Farley can be engaged to provide discretionary investment advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, Robbins Farley will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). Robbins Farley will generally provide services on an “assets under management” fee basis as a 3(38) advisor per the terms and conditions of a written agreement between the Plan and the Firm. Cash Positions Robbins Farley continues to treat cash as an asset class. As such, unless determined to the contrary by Robbins Farley, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Robbins Farley’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Robbins Farley may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Robbins Farley’s advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion Robbins Farley shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless Robbins Farley reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. The above does not apply to the cash component maintained within a Robbins Farley actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager and cash balances maintained for fee billing purposes. The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any Robbins Farley unmanaged accounts. Client Obligations In performing our services, Robbins Farley shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify Robbins Farley if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising our previous recommendations and/or services. Assets Under Management As of December 31, 2023, Robbins Farley has $186,365,662 in assets under management on a discretionary basis across 628 accounts. Cybersecurity Risk The information technology systems and networks that Robbins Farley and its third-party service providers use to provide services to Robbins Farley’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Robbins Farley’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Robbins Farley are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although Robbins Farley has established processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that Robbins Farley does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions.