Business Description We provide manager selection and supervision services to individuals, business, high-net-worth individuals and charitable organizations. The managers selected may trade in a variety of securities, including mutual funds, fixed income securities, equities, ETFs (including ETFs in the gold and precious metal sectors) and non-U.S. securities. As a registered investment adviser, we are held to the highest standard of client care – a fiduciary standard. As a fiduciary, we always put our client’s interests first and must fully disclose any potential conflict of interest. We do not directly hold customer funds or securities. A. Description of the Advisory Firm OT Financial, dba Turnstone Financial (hereinafter “TF”) is a Limited Liability Company organized in the State of Ohio in May 2010 and has been licensed in Ohio since 2014. The Principal Owner is Thomas Joseph Kleptz. B. Types of Advisory Services Selection of Other Advisers TF has discretion to choose third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, TF will always ensure those other advisers are properly licensed or registered as an investment adviser. TF conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. TF then makes investments with a third-party investment adviser by investing with the third-party adviser. TF will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Account Monitoring TF does provide advisory services without investment management to clients who elect to direct their own investments. In these situations, TF will execute the clients trades on their behalf. Services Limited to Specific Types of Investments TF limits its investment advice to selection of other advisers, and such sub-advisers may invest in mutual funds, fixed income securities, equities, ETFs (including ETFs in the gold and precious metal sectors) and non-U.S. securities, and may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment

advice to you regarding your retirement plan account or individual retirement account, we are 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions TF will tailor a program for each individual client. When meeting with clients we not only look at age, but family dynamics, financial goals of the client and their beneficiaries, their risk tolerance, future cash flow needs and future inheritances all come in to play when discussing risk tolerance. 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 TF on behalf of the client. 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 TF from properly servicing the client account, or if the restrictions would require TF to deviate from its standard suite of services, TF 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. TF does not participate in any wrap fee programs. E. Assets Under Management TF has $142,778,241.00 in discretionary assets under management as of December 2023.