A. Description of the Advisory Firm SJBenen Advisory, LLC (hereinafter “SJBenen”) is a Limited Liability Company organized in the State of Delaware. The firm was formed in March 2016, and the principal owner is Samson J Benen. B. Types of Advisory Services Portfolio Management Services SJBenen offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. SJBenen creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring SJBenen evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. SJBenen will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. SJBenen seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of SJBenen’s economic, investment or other financial interests. To meet its fiduciary obligations, SJBenen attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, SJBenen’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is SJBenen’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. SJBenen offers three account management tiers and sets the fee per the level of active management and complexity that goes into administering the account. SJBenen can combine management strategies in a single account and offer a blended fee for a hybrid management strategy. SJBenen is not explicitly offering breakpoints, i.e. reduced fees for accounts with more Assets Under Management, instead setting the fee based on the management style. Each prospective client has a unique set of circumstances and management fees are negotiable. Passive Management (Most simple) Products traded: Broad-based, low-fee index exchange-traded funds and open-ended mutual funds. Individual fixed income securities, including corporate bonds, preferred stock, and US treasury securities. Description of management style: Designed for long-term investors who desire maximum simplicity in their investments and can patiently ride out market cycles. Very low turnover in the portfolio means lower transaction costs for clients and less active trading duties for SJBenen. SJBenen will help select a suitable allocation to stock market indexes and fixed income securities and will be available for periodic consultation on financial planning topics. Long-only active management Products traded: All products in the Passive Management tier. In addition, limited use of options: Covered calls, and long-only spreads. Special situations in individual equities such as mergers and tender offers. Description of management style: Designed for clients looking for superior risk- adjusted returns to a simple passive buy-and-hold asset allocation strategy. SJBenen uses tactical asset allocation, investing client funds based on what is perceived to be attractive in the marketplace at any given time, rather than following a preset asset allocation. Long-only means that there is no naked short option writing and no short- selling employed in the management of the account. Turnover is based on market volatility and the degree to which financial asset prices shift around; however, this is not a high-churn or day-trading strategy. Long-short active management (Most complex) Products traded: All products in the

Long-Only Active Management tier. In addition, naked option writing, short-selling, leveraged ETFs, and futures. Description of management style: Designed for sophisticated investors looking for positive returns in a wide range of scenarios regardless of market direction, and who are comfortable with the risks and added complexity associated with these trading strategies. In addition to all strategies described in the Long-Only Management Tier, SJBenen also uses complex strategies, including futures and options on leveraged ETFs, to attempt to generate an absolute positive return in up and down markets alike. As with Long-Only Active Management, turnover is based on market volatility and the degree to which financial asset prices shift around; however, this is not a high-churn or day-trading strategy. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Subscription Services SJBenen provides a newsletter to its clients entitled “The Benen Report” but we are not charging a fee for a subscription. The newsletter makes general observations on the markets, the economy, and the world at large. While the newsletter may offer generalized advice, it will not give tailored advice or specific securities recommendations. Services Limited to Specific Types of Investments SJBenen generally limits its investment advice to fixed income securities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, and non-U.S. securities. SJBenen may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions SJBenen will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by SJBenen on behalf of the client. SJBenen may use “model portfolios” together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent SJBenen from properly servicing the client account, or if the restrictions would require SJBenen to deviate from its standard suite of services, SJBenen reserves the right to end the relationship. SJBenen will determine what types of financial products are suitable for a client’s portfolio, based on risk tolerance and overall financial planning considerations. For example, some clients may not want to participate in options, and that client's portfolio can be tailored not to receive an allocation of any option trades. SJBenen will determine suitability for options trading strategies as an alternative to traditional investing, with the understanding that many clients do prefer a simple, traditional asset management approach without the use of options or complex trading strategies. SJBenen will advise on non-securities related financial matters, including but not limited to: tracking personal assets, liabilities, and cash flows, real estate purchase and sale decisions, insurance policies, and topics related to estate planning and taxation. In a financial planning arrangement, SJBenen will provide tailored advice for 'Do-It- Yourself' investors who want to retain control over their investments but want occasional advisory services through hourly consultation. SJBenen will determine whether a client is better suited for a managed account or hourly consultation without assets directly under management. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. SJBenen does not participate in any wrap fee programs. E. Assets Under Management SJBenen has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 252,949,230 $0.00 December 2023