The Firm is an independent investment advisory practice and limited liability company formed as Parvin Asset Management, LLC in June 2021 with offices located at 401 E. 8th Street, Suite 213A, Sioux Falls, SD 57103. The owners of limited liability companies are called “members.” J. Steven Smith is the sole member and a managing director of Parvin. The Firm initiated operations in December 2000 as Swan Asset Management, LLC and began doing business as (“dba”) Parvin Asset Management in September 2017, continuing to use its dba name for general business purposes until October 2021. The Firm now operates as Parvin Asset Management, LLC and any references to Parvin include Swan Asset Management, LLC and Swan Asset Management, LLC dba Parvin Asset Management. As a money manager, rather than an investment consultant or financial planner, registered as an investment adviser with the SEC, all supervised investment persons must meet any requirements set forth in the Investment Advisers Act of 1940, as amended, and its accompanying rules and regulations. In addition, all supervised persons must meet the requirements of comparable statutes in states where Parvin may be registered and where such persons may act. The Firm provides investment supervisory services and gives continuous advice to its clients and makes investments for them based on the individual needs of each client. Investment supervisory services are provided on a discretionary basis. When a client grants Parvin investment and brokerage discretion, the Firm will have authority to determine, without obtaining specific client consent, (a) the securities to be bought and sold; (b) the amount of securities to be bought and sold; (c) the broker or dealer to be used, if not designated by the client; and (d) the commission rates to be paid. Investment management is guided by the objectives and restrictions articulated

by the client. To support the management responsibilities of a community bank trust department, Parvin also provides non- discretionary investment supervisory services with respect to clients of the bank. Since a potential conflict of interest may exist between the interests of non-discretionary clients and the interests of Parvin, the non- discretionary client is under no obligation to act upon the Firm’s recommendation in selecting investments. If non-discretionary clients elect to act on any of the recommendations, they are under no obligation to effect the transactions through Parvin. The Firm does not actively offer non-discretionary investment management services and currently limits these services to this single, unique client relationship. The Firm directs its efforts toward tailoring advisory services to the individual needs of clients based on their investment objectives. Clients may impose restrictions on investing in certain securities or types of securities and may impose other more general investment restrictions as described in Item 8. Parvin works to invest in those securities that are judged to achieve the objectives articulated by the client and strives to provide comprehensive, personalized service while adhering to any client-imposed restrictions. The Firm does not manage, sponsor, or participate in a wrap fee program. As of December 31, 2023, Parvin provided investment advisory services with respect to approximately $127.2 million of client assets under discretionary management and approximately $2.2 million of client assets under non-discretionary management. An affiliate of the Firm, Parvin Fund Management, LLC (“Parvin Fund Management”) serves as adviser to the Parvin Hedged Equity Solari World Fund and the Parvin Select Equity Solari World Fund (collectively, the “Funds”) and the Firm serves as sub-adviser. PAM FORM ADV PART II | 4 of 12