1N Capital offers a variety of advisory services, which include investment consulting and investment management services. Prior to 1N Capital rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with 1N Capital setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). 1N Capital filed for registration as an investment adviser in June 2020 and is wholly owned by Yen Wu. As of February 2, 2024, the firm has $106,430,286 in assets under management, all of which was managed on a discretionary basis. While this brochure generally describes the business of 1N Capital, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or other persons who provide investment advice on 1N Capital’s behalf and are subject to the Firm’s supervision or control. Investment Management Services 1N Capital manages client investment portfolios on a discretionary or non-discretionary basis. 1N Capital primarily allocates client assets among various exchange-traded funds (“ETFs”), individual equity securities, privately placed securities (including debt, equity and/or interests in pooled investment vehicles) independent investment managers (“Independent Managers”), and structured products in accordance with their stated investment objectives. Less frequently, the Firm will also advise on mutual funds, foreign exchange currency, fixed income and options. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage 1N Capital to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, 1N Capital directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. 1N Capital tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. 1N Capital consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify 1N Capital if there are changes in their financial situation or if they Page | 5 © MarketCounsel 2024 wish to place any limitations on the management of their portfolios. Clients can impose reasonable

restrictions or mandates on the management of their accounts if 1N Capital determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Use of Independent Managers As mentioned above, 1N Capital selects certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement with the designated Independent Manager. That agreement can be between the Firm and the Independent Manager (often called a subadvisor) or the client and the Independent Manager (sometimes called a separate account manager). In addition to this brochure, clients will typically also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. 1N Capital evaluates a variety of information about Independent Managers, which includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. 1N Capital also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. 1N Capital continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. 1N Capital seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Investment Consulting Services 1N Capital offers clients a broad range of investment consulting services, including advice about asset allocation and restricted securities. In performing investment consulting services, 1N Capital is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage 1N Capital to provide additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by 1N Capital under an investment consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising 1N Capital’s recommendations and/or services. Page | 6 © MarketCounsel 2024