A. Description of the Advisory Firm Harvest Capital Assets, LLC (hereinafter “HCA”) is a Limited Liability Company organized in the State of New York. The firm was formed in August 2010, and the principal owner is Alexander Leo Skabry. B. Types of Advisory Services Portfolio Management Services HCA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. 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 HCA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. HCA will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. HCA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of HCA’s economic, investment or other financial interests. To meet its fiduciary obligations, HCA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, HCA’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 HCA’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 HCA generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements, although HCA primarily recommends individual securities - stocks to a majority of its clients. HCA may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions HCA offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon individual needs which outlines each client’s current situation (income, tax levels, and risk tolerance levels). 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 HCA from properly servicing the client account, or if the restrictions would require HCA to deviate from its standard suite of services, HCA 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. HCA does not participate in any wrap fee programs. E. Assets Under Management HCA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $58,000,000.00 $0.00 December 2023