A. Description of the Advisory Firm KDM Capital LLC (hereinafter “KDM”) is a Limited Liability Company organized in the State of New York. The firm was formed in September 2016, and the principal owner is Andre Lamar McClure. B. Types of Advisory Services Portfolio Management Services KDM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. KDM 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 KDM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. KDM 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. KDM seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of KDM’s economic, investment or other financial interests. To meet its fiduciary obligations, KDM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, KDM’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 KDM’s policy to allocate investment opportunities and transactions it

identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Services Limited to Specific Types of Investments KDM generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, hedge funds, private equity funds, ETFs, treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements, although KDM primarily recommends long term growth. KDM may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions KDM 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 KDM on behalf of the client. KDM may use model allocations 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 KDM from properly servicing the client account, or if the restrictions would require KDM to deviate from its standard suite of services, KDM reserves the right to end the relationship. 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. KDM does not participate in any wrap fee programs. E. Assets Under Management KDM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 44,747,640.00 $0.00 December 2022