A. The Company 8th Street Investments, LLC (“8th Street” or the “firm”), a Virginia limited liability company founded in 2008, was registered with the U.S. Securities and Exchange Commission (“SEC”) from 2009 to 2012. From 2012 to 2021, 8th Street was registered with the Commonwealth of Virginia and District of Columbia. Since June 2021, 8th Street has been registered with the SEC. The principal owners of 8th Street are Lisa Pendley and Michael Shea. B. Advisory Services 8th Street offers the following investment advisory services: Investment Management Services 8th Street offers ongoing Investment Management Services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Investment Management Services include, but are not limited to, the following:
• Establishing an Investment Policy Statement – 8th Street, in conjunction with the client, will develop a statement that summarizes the client’s investment goals and objectives along with the broad strategy[ies] to be employed to meet those objectives.
• Financial Planning – Investment Management Services includes basic financial planning which may contain advice regarding asset allocation, the selection of investments, cash flow analysis, retirement advice and educational planning.
• Portfolio Construction – 8th Street will develop a strategic asset allocation for the client based on the client’s risk profile and investment guidelines and is intended to meet the stated goals and objectives of the client.
• Investment Management and Supervision – 8th Street will provide investment management and ongoing oversight of the client’s portfolio and overall account. Investment Management Services will be provided on either a discretionary or non- discretionary basis. For discretionary accounts, clients will be required to give 8th Street authority to manage the client's assets in accordance with what 8th Street deems to be in the client's best interest based on the client’s investment objectives and guidelines. Clients will retain individual ownership of all securities in their account. Financial Planning and Consulting Services If a client desires to obtain financial planning apart from the basic planning services provided as part of portfolio management services, 8th Street also provides financial planning as a separate service. 8th Street will typically provide a variety of financial planning services to individuals and families. Services are offered in several areas of a client’s financial situation, depending on their goals, objectives and financial situation. Financial planning services can be provided in one or both of the following manners: Planning Financial planning will involve preparing a financial plan for clients based on the client’s financial goals and objectives. This planning may encompass one or more areas of need, including, but not limited to, investment planning, retirement planning, personal savings, education savings and other areas of a client’s financial situation. A financial plan developed for the client will usually include general recommendations for a course of activity or specific actions to be taken by the client. For example, recommendations may be made that the client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. 8th Street may also refer clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, 8th Street will provide a written summary of client’s financial situation, observations, and recommendations. Plans are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Consulting Clients can also receive financial advice on a more limited basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, reviewing a client's existing portfolio, or any other specific topic. 8th Street also provides specific consultation and administrative services regarding investment and financial concerns of the client. Additionally, 8th Street provides advice on non- securities matters. Generally, this is in connection with the rendering of estate planning, insurance and/or annuity advice. 8th Street also may provide investment advice to clients relative to variable life/annuity

products that they may own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that may not be held by the client’s primary custodian. In so doing, 8th Street may recommend the allocation of client assets among the various investment options that are available with the product. Clients retain absolute discretion over the implementation of these recommendations. Client assets are maintained at the specific insurance company or custodian designated by the product, and 8th Street does not provide ongoing investment monitoring of such assets. For these more limited engagements, 8th Street may not provide a written summary. Recommendations are not limited to any specific product or service offered by a broker- dealer or insurance company. Financial Planning Disclosures Should a client choose to implement the financial planning recommendations made by 8th Street, 8th Street may recommend its own services or that of other professionals (i.e., attorney, accountant, insurance agent, and/or stockbroker). In performing its services, 8th Street is not required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely on such information. Clients are advised that a conflict of interest exists if 8th Street recommends its own services. The client is under no obligation to act upon any of the recommendations made by 8th Street under a financial planning engagement and/or engage the services of any such recommended professional, including 8th Street or its investment adviser representatives. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation made by 8th Street or its investment adviser representatives. 8th Street shall cooperate with any attorney, accountant, broker or other adviser chosen by the client with regard to implementation of any such recommendations. C. Client Tailored Services and Client Imposed Restrictions 8th Street’s investment management services are tailored to meet the specific needs of each client. In order to provide appropriately individualized services, 8th Street will work with each client to obtain information regarding the client’s financial circumstances, investment objectives, overall financial condition, income and tax status, personal and business assets, risk profile and other information regarding the client’s financial and investment needs. At least annually, 8th Street will review with clients their financial circumstances, investment objectives and risk profile. In order for 8th Street to provide effective investment management services, it is critical that clients provide accurate and complete information to 8th Street and inform 8th Street anytime such information needs to be updated or anytime there is a change in their financial circumstances, investment objectives and/or risk profile. Generally, clients are permitted to impose reasonable restrictions on investing in certain securities or types of securities in their advisory accounts, provided, however, that some restrictions may not be accommodated when utilizing Exchange Traded Funds or mutual funds. In addition, a restriction request may not be honored if it is fundamentally inconsistent with 8th Street’s investment philosophy, runs counter to the client’s stated investment objectives, or would prevent 8th Street from properly servicing client accounts. Whether clients will be able to place reasonable restrictions on the types of investments which will be made on the client's behalf is at the sole discretion of 8th Street. D. Wrap Fee Programs Under a wrap fee program, advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and transaction services (e.g., execution of trades) are provided for one fee. These portfolio solutions are generally pre- configured with limited flexibility. This is different than traditional investment management programs whereby services are provided for a fee, but transaction services are billed separately on a per-transaction basis. 8th Street does not offer clients the option of investing in wrap-fee programs. E. Assets Under Management As of December 31, 2023, the total amount of client assets managed by 8th Street is approximately $162,303,533, of which $162,290,840 are managed on a discretionary basis and $12,693 on a non-discretionary basis.