This Disclosure document is being offered to you by J. Hagan Capital, Inc. (“JHC” or “Firm”) about the investment advisory services we provide. It discloses information about the services that we provide and the way those services are made available to you, the client. JHC became a Registered Investment Adviser in the State of Kentucky in September 2013 and was registered as an Investment Advisor with the SEC in June 2021. Jonathan Hicks is the owner and Chief Compliance Officer of the Firm. Our Firm provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing investment management and consulting services. Investment advisory services are initiated only after you and JHC execute an investment management agreement. INVESTMENT MANAGEMENT AND SUPERVISION SERVICES Our Firm manages advisory accounts on a discretionary and non-discretionary basis. Our Firm works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. JHC will then construct a portfolio, consisting of traditional and alternative asset classes, as well as insurance to achieve Client goals. Investments may include private placements, traded and non-traded real estate investment trusts (“REITs”), and other types of investments necessary to achieve the Clients investment goals. The Advisor may employ traditional investments, including individual cash, stocks, individual bonds, mutual funds, and exchange-traded funds (“ETFs”), as necessary to support a particular Client’s investment goals. Once we have determined the types of investments to be included in a client’s portfolio and have allocated the assets, we provide ongoing investment review and management services. It is the client’s obligation to notify us immediately if circumstances have changed with respect to their goals. For discretionary accounts, once we have determined a profile and investment plan with a client, we will make changes to the portfolio, as we deem appropriate, to meet client financial objectives. We will execute the day-to-day transactions without seeking prior client consent but within the expected investment guidelines. Account supervision is guided by the client’s written profile and investment plan. We will accept accounts with certain trading restrictions if circumstances warrant. If a non-discretionary relationship is in place, calls will be placed presenting the recommendation made and only upon your authorization will any action be taken on your behalf. Our Firm has limited authority to direct the custodian to deduct our investment advisory fees from accounts, but only with the appropriate written authorization from clients. Clients may engage us to advise on certain investment products that are not maintained at our Firm’s recommended custodian, such as variable life insurance, annuity contracts, and assets held in employer sponsored retirement plans. Where appropriate, we provide advice about any type of held away account that is part of a client portfolio. You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks exist that adversely affect an account’s performance. This could result in capital losses in your account. Clients engaging in Investment Management Services will have access to the following services: MARCH 2024 | PAGE 4 PARTICIPANT ACCOUNT MANAGEMENT (PONTERA) We use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly, and allocation changes will be made as deemed necessary. EP GURU ESTATE PLANNING SOFTWARE Our Firm offers support for estate planning through EP Guru, an online estate planning tool. Through EP Guru, clients can have trusts, wills, and other estate planning documents prepared by local attorneys. Our Firm does not provide estate planning advice and only assists clients with the EP Guru discovery process and notarizes the clients’ completed documents. Clients can directly engage EP Guru for estate planning services without using the services of our Firm. Our Firm does not currently offer financial planning services alone. However, our Firm reserves the right to offer planning services in a negotiated situation where it benefits the client and our Firm. FINANCIAL PLANNING JHC will typically provide a variety of financial planning services to individuals and families, pursuant to a written financial planning or consulting agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives, and financial situation. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. Our specific services in preparing your plan may include: § Review and clarification of your financial goals. § Assessment of your overall financial position including cash flow, balance sheet, investment strategy, risk management, and estate planning. § Creation of a unique plan for each goal you have, including personal and business real estate, education, retirement or financial independence, charitable giving, estate planning, business succession, and other personal goals. § Development of a goal-oriented investment plan, with input from various advisors to our clients around tax suggestions, asset allocation, expenses, risk, and liquidity factors for each goal. This includes IRA and qualified plans, taxable, and trust accounts that require special attention. § Design of a risk management plan including risk tolerance,

risk avoidance, mitigation, and transfer, including liquidity as well as various insurance and possible company benefits. § Crafting and implementation of, in conjunction with your estate and/or corporate attorneys as tax advisor, an estate plan to provide for you and/or your heirs in the event of an incapacity or death. MARCH 2024 | PAGE 5 Services rendered to 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. Such services include various reports on specific goals and objectives or general investment and/or planning recommendations, guidance to outside assets, and periodic updates. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. TAX PLANNING Tax planning services offered through JHC. JHC will assist you in the development of a multi-year income tax plan after careful consideration of your objectives and present financial situation. This process begins with the preparation of a comprehensive financial plan. Based on this analysis, we will recommend strategies to implement today that can have a positive impact on taxes due in future years, especially during retirement. Tax return preparation is not included in this service but can be obtained through JHC at an additional cost. SUB-ADVISORY SERVICES & THIRD-PARY MANAGER SERVICES If deemed appropriate, our Firm will utilize the services of a Sub-Advisor (“SMA” or “Manager”) or Independent Third-Party Manager (“ITPM” or “Manager”) to manage your accounts. Investment recommendations and securities trading will only be offered by or through the chosen SMA or ITPM. Our Firm will not advise on any specific securities concerning this service. Before referring you, our Firm will provide initial due diligence on SMA and ITPMs and ongoing reviews of their management of your accounts. To assist in selecting an SMA or ITPM, our Firm will gather information about the Client’s financial situation, investment objectives, and reasonable restrictions to be imposed upon the account management. Our Firm will periodically review the Manager reports provided to the Client. We will periodically contact the Client to review their financial situation and objectives, communicate information to the Manager as warranted, and assist you in understanding and evaluating the services provided. The Client will be expected to notify our Firm of any changes in their financial situation, investment objectives, or account restrictions that could affect their financial standing. By executing an Investment Advisory Agreement with our Firm, the Client gives our Firm the discretionary authority to hire or fire the Manager and to allocate assets among Managers without obtaining consent. The services provided by the SMA and ITPM include:
• Assessment of your investment needs and objectives
• Implementation of an asset allocation
• Delivery of suitable style allocations (e.g., Income, Large Cap, Small Cap, Growth, Value, etc.)
• Facilitation of portfolio transactions
• Ongoing monitoring of investment vehicles’ performance
• Review of accounts for adherence to policy guidelines and asset allocation
• Reporting of your portfolio activity. MARCH 2024 | PAGE 6 Each Manager generally has minimum account requirements that will vary among Managers. Account minimums are usually higher for fixed-income accounts than for equity-based accounts. A complete description of Manager’s services, fee schedules, and account minimums will be disclosed in the Manager’s disclosure brochure, which will be provided to you before or when an agreement for services is executed, and the account is established. DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. A client or prospect leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Our Firm may recommend an investor roll over plan assets to an IRA for which our Firm provides investment advisory services. As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their previous employer or roll over the assets to a plan sponsored by a new employer will generally result in no compensation to our Firm. Our Firm therefore has an economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, which presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm will consider before recommending a rollover, including but not limited to: (i) the investment options available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any. Our Firm’s Chief Compliance Officer remains available to address any questions that a client or prospective client has regarding the oversight. WRAP FEE PROGRAM Our Firm does not manage or place Client assets into a wrap fee program. ASSETS As of December 31, 2023, our Firm manages a total of $169,338,280 in discretionary assets and $16,251,896 in non-discretionary assets for a total of $185,590,176 in Assets Under Management.