IT EM 4 Who We Are Mastodon Advisory Group, LLC (hereinafter referred to as “Mastodon,” “the Company,” “we,” “us” and “our”) is a fee-based registered investment advisor1, organized as a Texas Limited Liability Company in 2016, to offer advisory services designed to assist you, our client2, achieve long-term growth and capital appreciation in your investment portfolio. Owners The following person controls the Company: Name Title CRD# Warren Bane Managing Member & Chief Compliance Officer 4958383 Our Mission As a boutique advisor, our mission is to be the trusted advocate you turn to for clear, objective, and sound investment advice when it comes to high-net-worth clients and special needs trusts and planning. We will do our best to keep you focused on where you want to go, offer advice on how best to get there, and continually remind you of the importance of maintaining a disciplined financial strategy to realize your financial goals. Assets Under Management As of December 31, 2022, our assets under management totaled: Discretionary Accounts ...................................................... $199,037,942 We do not offer non-discretionary investment management services. What We Do We provide investment solutions that stress the importance of you making fiscally responsible decisions and disciplined economic choices in your personal life so that together we can effectively help you establish a financial course to fulfill today’s monetary needs, tomorrow’s retirement dreams, and establish a strategy to build a lasting legacy for future generations. The focus of our management begins with identifying your standards of living and quality of lifestyle expectations. We will accomplish this through an initial Discovery Meeting where we will review the financial documents we asked you to bring for discussion. Together questions will be asked, information shared, and an evaluation made as to whether we should move to the next step. 1 The term “registered investment advisor” is not intended to imply that Mastodon Advisory Group, LLC has attained a certain level of skill or training. It is used strictly to reference the fact that we are “registered” as a licensed “investment advisor” with the United States Securities & Exchange Commission – and “Notice Filed” with State Regulatory Agencies that have limited regulatory jurisdiction over our business practices. 2 A client could be an individual and their family members, a family office, a foundation or endowment, a charitable organization, a corporation and/or small business, a trust, a guardianship, an estate, or any other type of entity to which we choose to give investment advice. During the meeting, we will:  Learn about your core values and guiding principles.  Seek to understand your financial concerns and how you have been addressing them.  Discover your financial objectives and what success looks like for you.  Share how our investment approach fits into a broader financial strategy; and,  Create an internal profile consisting of your current income and expenses, assets, career objectives, investment goals, risk tolerance and investment time horizon, targeted rate of return, and prior investment experience, along with personal information about your relationships, your values, and interests. Moving forward, should you choose to engage us for our advisory services, we will begin the process of identifying your life objectives (i.e., core values, family, monetary needs, future plans, etc.). From this we will develop, at minimum, an Investment Policy Statement (“IPS”) that outlines what asset mix is most suitable for your unique investment expectations and risk tolerance. Our arrangements under a co-advisory relationship with Cambridge Investment Research Advisors, Inc. (“CIRA”), as sponsor of the WealthPort Wrap program, allows for greater flexibility to work with you in developing the allocation objectives for your portfolio based on your investment parameters without the added burden of back-office compliance for billing and/or reporting. Under the WealthPort Wrap program we will have access to model portfolios, model managers, strategists, other money managers, and trading services to better guide you on future investments. Information regarding our management fee structure is disclosed under “Portfolio Management Fee” in Item 5, “Fees & Compensation” and further description of our investment strategies under Item 8, “Methods of Analysis, Investment Strategies & Risk of Loss”. FEES & COMPENSATION IT EM 5 Discovery Meeting The Discovery Meeting is offered without cost or obligation after an initial introductory phone call. We schedule this Discovery Meeting for us to learn about each other. The objectives we strive to accomplish with you during this meeting are to:  Diagnose your current financial need.  Address your financial concerns and answer your questions on how we can assist you.  Recommend financial resolutions aimed at lowering costs, reducing risks, increasing expected returns, and/or increasing tax efficiency to improve the likelihood of successfully achieving your goal.  Explain our investment methodology and how our investment strategies work.  Explain the benefits of financial planning and how a broad evaluation of your wealth management needs is beneficial beyond just managing your investable assets. From the Discovery Meeting, our objective will be to move forward under an

advisory contract. We will prepare the necessary agreements to perform the desired service. If, however, you do not wish to engage us for advisory services, you will be responsible for implementing any recommendations coming out of the Discovery Meeting. All advisory services discussed will have been concluded and we are not responsible to implement the advice or for any on-going supervision, monitoring, and/or reporting. Portfolio Management Fee Our portfolio management services are provided on an asset-based fee arrangement. Regardless of the portfolio account size, our management fee will not exceed 1.20% annually. The management fee will be calculated monthly or quarterly in advance or in arrears depending on your preference. To calculate the monthly or quarterly management fee, the aggregate fair market value of your portfolio on the last business day of the previous calendar month or quarter is multiplied by the annual management fee of 1.20%, divided by 365 (the number of days in a year), and then multiplied by the number of days in the monthly or quarterly billing period. If your account is established on a date other than the last day of a calendar month or quarter, the management fee is prorated for the initial billing period. We retain discretion to negotiate the management fee on a client-by-client basis depending on the size, complexity, and nature of the portfolio managed. All management fees will be fully disclosed to you in an advisory agreement prior to conducting any portfolio management services. A minimum initial investment of $25,000 will be required for you to open a managed account; however, we retain the right to waive or reduce this minimum if we feel circumstances are warranted. To terminate our portfolio management services, either party (you or us), by written notification to the other party, may terminate the Investment Advisory Agreement at any time. Such written notification should include the date the termination will go into effect along with any final instructions on the account (e.g., liquidate the account, finalize all transactions and/or cease all investment activity). In the event termination does not fall on the last day of a billing period, you shall be entitled, if your management fee was paid in advance, to a pro-rated refund of the prepaid management fee based upon the number of days remaining in the billing period after the termination notice goes into effect. If your management fee was paid in arrears, you will be billed a prorated management fee based upon the number of days in the billing period your account was managed. Once the termination of investment advisory services has been implemented, neither party has any obligation to the other – we no longer earn management fees or give investment advice and you become responsible for making your own investment decisions. Wrap Fee Arrangements Our management fee will be included in a “wrap fee” with CIRA, as sponsor of the WealthPort Wrap, as part of a wrap fee program. The maximum fee that can be billed to your account is 2.25%, which includes our fee, the CIRA’s fee, and the platform fee. A “wrap fee” is the bundling of brokerage transaction costs and advisory fees into a comprehensive asset-based annual management fee (See Item 12, “Brokerage Practices” for more information on the wrap program). You will want to consult the CIRA’s ADV Part 2A Appendix 1: Wrap Fee Program Brochure, which we will provide you prior to, or at the same time as, opening an account, for their policies on how they will handle your account; such as, billing, deposits and withdrawals, fee exclusions, termination, and any other unique advisory costs associated with their service since we do not take sole discretion over the assets managed in your account and we do not handle any of the billing. We will discuss these arrangements with you when we go to open your account with CIRA; however, you are also encouraged to read their terms for management on your own. Wrap Fee Disclosures We feel a wrap fee program arrangement provides greater access to investment tools and products; however, prior to accepting our recommendation to be included in this program you should consider the following:  Wrap fee programs can be more expensive than traditional custodial arrangements. You should consider the costs and potential benefits of this arrangement as compared to paying commissions on a per-trade basis and your overall investment objectives and goals.  The financial institutions reserve the right to disallow any account to be party to the wrap fee arrangement if they determine the trading activity in the account is excessive or if the trading activity is too low to justify an asset-based fee.  Wrap fee programs do not cover all expenses that may occur in your account3. You can request a list of possible fees that can be charged to your account that are not covered by this asset-based fee arrangement.  Wrap fee arrangements are not for everyone. You should consider your trading patterns and the investment strategies used in the management of your portfolio; including, the frequency of trading and the number and size of transactions. PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT IT EM 6 We do not charge fees based on a share of capital gains or the capital appreciation of the assets held in your accounts.