Marcado Asset Management LLC (hereinafter “Marcado Asset Management”) is a registered investment adviser based in San Antonio, Texas. We are a limited liability company formed under the laws of the state of Texas. We have been providing investment advisory services since 2017. Nathan J. Sharp, Manager, Principal and Chief Compliance Officer and Andrew W. Bronson, Manager and Principal own Marcado Asset Management. Retirement Plan Services Currently, Marcado Asset Management offers the following retirement plan consulting and fiduciary services to employer sponsored and other qualified plans, their sponsors, and other named fiduciaries. Services are offered on an ongoing or per project basis. Consulting Services Retirement Plan Consulting Services are designed to allow our IARs to assist the Sponsor in meeting his/her fiduciary duties to administer the plan in the best interests of plan participants and their beneficiaries. Retirement Plan Consulting Services may only be performed so that they would not be considered fiduciary services under ERISA. The Sponsor may elect for our investment adviser representatives to assist with any of the following services: Administrative Support  Assist Sponsor in reviewing objectives and options available through the plan  Review plan committee structure and administrative policies/procedures  Recommend participant education and communication policies under ERISA 404(c)  Assist with development/maintenance of fiduciary audit file and document retention policies  Deliver fiduciary training periodically or upon reasonable request  Assist with coordinating participant disclosures under 404(a)  Recommend procedures for responding to participant requests Service Provider Support  Assist fiduciaries with a process to select, monitor and replace service providers  Assist fiduciaries with review of Covered Service Providers (“CSP”) and fee benchmarking  Provide reports and/or information designed to assist fiduciaries with monitoring CSPs  Assist with use of ERISA Spending Accounts or Plan Expense Recapture Accounts to pay CSPs  Assist with preparation and review of Requests for Proposals and/or Information  Coordinate and assist with CSP replacement and conversion Investment Monitoring Support  Periodic review of investment policy in the context of plan objectives  Assist the plan committee with monitoring investment performance  Provide analysis of investment managers and model portfolios, if applicable  Assist with Designated Investment Managers (DIMs) and/or third-party advice providers as necessary  Educate plan committee members, as needed, regarding replacement of DIA(s) and/or QDIA(s) Participant Services  Facilitate group enrollment meetings and coordinate investment education  Assist plan participants with financial wellness education, retirement planning and/or gap analysis Non-discretionary Fiduciary Services These services are designed to allow the Sponsor to retain full discretionary authority or control over assets of the Plan. We will solely be making recommendations to the Sponsor. We will perform these non-discretionary investment advisory services through our IARs, and may charge a fee for these fiduciary services, as described in this Form ADV and the Agreement. We will perform these investment advisory services to the Plan as a fiduciary defined under ERISA Section 3(21) and we will act with the degree of diligence, care, and skill that a prudent person rendering similar services would exercise under similar circumstances. The Sponsor may engage us to perform one or more of the following non-discretionary investment advisory services: Investment Policy Statement (“IPS”) We will review with Sponsor the investment objectives, risk tolerance and goals of the Plan. If the Plan does not have an IPS, we will provide recommendations to Sponsor to assist with establishing an IPS. If the Plan has an existing IPS, we will review it for consistency with the Plan’s objectives. If the IPS does not represent the objectives of the Plan, we will recommend to Sponsor revisions to align the IPS with the Plan’s objectives. Where engaged to do so, we will also review with Sponsor the funding requirements and cash flow needs of the Plan and will develop for approval by the Sponsor an IPS, which contains criteria from which we will select, monitor and replace the Plan’s investments. We will conduct a periodic review of the IPS with the Sponsor. Sponsor will authorize us to collect information from the Plan’s recordkeeper and actuary (if applicable), which is necessary to perform the IPS review, including, but not limited to, the Plan’s interest crediting rate (if applicable) and changes in the Sponsor’s employee demographics which may impact the Plan’s IPS. Advice Regarding Designated Investment Alternatives (“DIAs”) Based on the Plan’s IPS or other guidelines established by the Plan, we will review the investment options available to the Plan and will make recommendations to assist Sponsor with selecting DIAs to be offered to Plan participants. Once Sponsor selects the DIAs, we will, on a periodic basis and/or upon reasonable request, provide reports and information to assist Sponsor with monitoring the DIAs. If a DIA is required to be removed, we will provide recommendations to assist Sponsor with replacing the DIA. Advice Regarding Model Asset Allocation Portfolios (“MODELS”) Based on the Plan’s IPS or other guidelines established by the Plan, we will make recommendations to assist Sponsor with creating risk-based Models comprised solely among the Plan’s DIAs. Once Sponsor approves the Models, Advisor will provide reports, information, and recommendations, on a periodic basis, designed to assist Sponsor with monitoring the Models. Upon reasonable request, and depending upon the capabilities of the recordkeeper, we will make

recommendations to Sponsor to reallocate and/or rebalance the Models to maintain their desired allocations. Advice Regarding Third-Party Advisors and/or Managers Based on the Plan’s IPS or other investment guidelines established by the Plan, we will review the third-party investment managers available to the Plan and will make recommendations to assist Sponsor with selecting a third-party advisor or investment manager to manage some or all of the Plan’s investments. Once Sponsor approves the recommendation, we will provide reports, information, and recommendations, on a periodic basis, designed to assist Sponsor with monitoring the advisor/manager. If the IPS criteria require any manager to be removed, we will provide recommendations to assist Sponsor with evaluating replacements. Advice Regarding Qualified Default Investment Alternatives (“QDIAS”) Based on the Plan’s IPS or other guidelines established by the Plan, we will review the investment options available to the Plan and will make recommendations to assist Sponsor with selecting or replacing the Plan’s QDIA(s). Participant Investment Advice We will meet with Plan participants, upon reasonable request, to collect information necessary to identify the participant’s investment objectives, risk tolerance, time horizon, etc. We will provide recommendations to assist the participant with his/her Plan account. The participant retains sole discretion over the investment of their account. Advice Regarding Investment of Trust Fund Based on the Plan’s IPS or other investment guidelines established by the Plan, we will review the investment options available to the Plan and recommend to Sponsor investments for the Plan. We will provide reports, information, and recommendations, on a periodic basis, designed to assist Sponsor with monitoring the Plan’s investments. If the IPS criteria require any investment(s) to be removed, we will recommend to Sponsor replacement investment(s). Discretionary Fiduciary Services Where engaged by the Sponsor, we will perform discretionary investment advisory services through our IARs, and may charge a fee for these fiduciary services, as described in this Form ADV and the Agreement. We will perform these investment advisory services to the Plan as a fiduciary defined under ERISA Section 3(38) and we will act with the degree of diligence, care, and skill that a prudent person rendering similar services would exercise under similar circumstances. The Sponsor may engage us to perform one or more of the following discretionary investment advisory services: Investment Policy Statement (“IPS”) We will review with Sponsor the investment objectives, funding requirements, cash flow needs and goals of the Plan and will develop for approval by the Sponsor an IPS, which contains criteria from which we will select, monitor, and replace the Plan’s investments. We will conduct a periodic review of the IPS with the Sponsor. Sponsor will authorize us to collect information from the Plan’s recordkeeper and actuary (if applicable), which is necessary to perform the IPS review, including, but not limited to, the Plan’s interest crediting rate (if applicable) and changes in the Sponsor’s employee demographics which may impact the Plan’s IPS. Sponsor will notify us in writing of any modifications it may make to the IPS as well as any specific investment restrictions applicable thereto. Sponsor shall also inform us in writing of any changes in the funding policy and status applicable with respect to the Plan, including its cash disbursement requirements. Management of Trust Fund Based on the Plan’s IPS or other investment guidelines established by the Plan, we will review the investment options available to the Plan and select investments for the Plan on a discretionary basis. We will provide reports, information, and recommendations, on a periodic basis, designed to assist Sponsor with monitoring us in our capacity as an “investment manager” as that term is defined under Sec. 3(38) of ERISA. If the IPS criteria require any investment(s) to be removed, we will replace the investment(s) on a discretionary basis. Selection and Replacement of Third-Party Advisors and/or Managers Based on the Plan’s IPS or other investment guidelines established by the Plan, we will review the third-party investment advisors/managers available to the Plan and select a third-party investment advisor/manager to manage some or all of the Plan’s investments. We will provide reports, information, and recommendations, on a periodic basis, designed to assist Sponsor with monitoring the advisor/manager. If the IPS criteria require any advisor/manager to be removed, we will replace the advisor/manager. Selection, Monitoring & Replacement of DIAs We will review with Sponsor the investment objectives, risk tolerance and goals of the Plan and provide to Sponsor an IPS that contains criteria from which we will select, monitor and replace the Plan’s DIAs. Once approved by Sponsor, we will review the investment options available to the Plan and will select the Plan’s DIAs in accordance with the criteria set forth in the IPS. On a periodic basis, we will monitor and evaluate the DIAs and replace any DIA(s) that no longer meet the IPS criteria. Selection, Monitoring & Replacement of QDIA(s) Based upon the options available to the Plan, we will select, monitor, and replace the Plan’s QDIA(s) in accordance with the IPS. We will not, however, be the “QDIA Manager” as that term is defined under ERISA. Wrap Fee Programs We do not sponsor, manage, or participate in any wrap fee programs. Assets Under Management As of December 31, 2022, we had approximately $18,000,000 in regulatory assets under management on a discretionary basis. We do not have any regulatory assets under management on a non-discretionary basis.