A. Description of the Advisory Firm 724 Capital, LLC (hereinafter “724 Capital”) is a Limited Liability Company organized in the State of Ohio. The firm was formed in September 2021, and the principal owner is 724 Holdings, LLC. B. Types of Advisory Services Portfolio Management Services 724 Capital offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. 724 Capital creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. 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 724 Capital evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. 724 Capital will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. 724 Capital seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of 724 Capital’s economic, investment or other financial interests. To meet its fiduciary obligations, 724 Capital attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, 724 Capital’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 724 Capital’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. 724 Capital 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, 724 Capital will always ensure those other advisers are properly licensed or registered as an investment adviser. 724 Capital 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. 724 Capital then makes investments with a third-party investment adviser by investing with the third-party adviser. 724 Capital will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Pension Consulting Services

724 Capital offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: • identifying investment objectives and restrictions • providing guidance on various assets classes and investment options • recommending money managers to manage plan assets in ways designed to achieve objectives
• monitoring performance of money managers and investment options and making recommendations for changes
• recommending other service providers, such as custodians, administrators and broker-dealers • creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Services Limited to Specific Types of Investments 724 Capital generally limits its investment advice to mutual funds, fixed income securities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds and private placements. 724 Capital may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions 724 Capital will tailor a program for each individual client. 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 724 Capital on behalf of the client. 724 Capital may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. 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 724 Capital from properly servicing the client account, or if the restrictions would require 724 Capital to deviate from its standard suite of services, 724 Capital reserves the right to end the relationship. D. Wrap Fee Programs 724 Capital acts as the sponsor for a wrap fee program, which is an investment program where the client pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. However, this brochure describes 724 Capital’s non- wrap fee advisory services; clients utilizing 724 Capital’s wrap fee portfolio management should see 724 Capital’s separate Wrap Fee Program Brochure. E. Assets Under Management 724 Capital has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $197,382,852 $0 December 2023