A. Firm Information Bellingham Capital Management (“BCM” or the “Advisor”) is a Registered Investment Advisor with the Securities and Exchange Commission and is organized as an S Corporation under the laws of the State of Washington. BCM began its business on November 9, 2009 and was founded by Brian Smith, President. Its principal owners are Brian A. Smith (CRD #3149295), Eric G. Petersen (CRD #6244785), and Kerri H. Russ (CRD #6416017). B. Advisory Services Offered BCM offers investment advisory services to individuals, high net worth individuals, trusts and estates, corporations, and charitable foundations (each referred to as a “Client”). Advisor as Fiduciary: 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, and 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 must 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. Discretionary Investment Advisory Services BCM provides investment advisory solutions for its Clients. This is achieved through regular personal Client contact and interaction while providing discretionary investment management. BCM works with each Client to identify their investment goals and financial situation in order to select a portfolio allocation or model. BCM constructs portfolios, consisting of individual stocks, bonds, mutual funds, exchange-traded funds (“ETFs”), options and/or any other instrument deemed appropriate to achieve the Client’s investment goals. BCM’s investment strategy is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held less than one year. BCM will construct, implement, monitor and manage the portfolio according to the client’s goals or instructions. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, to the extent that these restrictions do not impair BCM’s ability to effectively manage a Client’s account. If Client restrictions are deemed obstructive, BCM may move the account to a non-discretionary or unmanaged status. BCM evaluates and selects ETFs and mutual funds for inclusion in Client portfolios only after applying their internal due diligence process. BCM may redistribute investment allocations to diversify the portfolio. BCM may increase or decrease sector or asset class weightings. The Advisor may employ cash positions as a possible hedge against market movement, which may adversely affect the portfolio. BCM may sell positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk, exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, reallocation in anticipation of a better investment opportunity, or any risk deemed unacceptable for the Client’s risk tolerance. Prior to rendering investment advisory services, BCM will ascertain, in conjunction with the Client, the Client’s financial situation, risk tolerance, and investment objective[s]. Page 5 BCM will provide investment advisory and portfolio management services but will not provide securities custodial or other administrative services. At no time will BCM accept or maintain custody of a Client’s funds or securities. All Client assets will be managed within their designated brokerage account or pension account pursuant to the Client Investment Advisory Agreement.

Financial Planning and Consulting Services BCM makes available financial planning and financial consulting services pursuant to a written Financial Planning and Consulting Services Agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives and financial situation. BCM offers financial planning and financial consulting services on a variety of topics, including:
• Retirement/financial independence plans
• Budgeting
• Debt management
• Business sale or succession planning
• Estate planning
• Education planning
• Risk management
• Employee stock option planning
• Real estate
• Investment Policy Statements BCM will typically prepare a plan for financial planning and consulting clients according to their needs and objectives. The Client provides information related to cash flow, assets, liabilities, goals, and objectives, then the Advisor and Client discuss a plan and recommendations. BCM may also refer Clients to an accountant, attorney, or other specialist as appropriate for their unique situation. For consulting or ad-hoc engagements, the Advisor might not provide a written summary. Financial planning and consulting recommendations pose a potential conflict between the interests of the Advisor and the interests of the Client. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to effect transactions through the Advisor. C. Tailored Service Prior to engaging BCM to provide advisory services, each Client is required to enter into an Agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Policy Statement – BCM, in connection with the Client, may develop a statement that summarizes the Client’s investment goals and objectives along with the broad strategy[ies] to be employed to meet the objectives. An Investment Policy Statement generally includes specific information on the Client’s stated goals, time horizon for achieving the goals, investment strategies, Client risk tolerance and any restrictions imposed by the Client. Page 6
• Asset Allocation – BCM has developed portfolio models targeted to meet the investment objectives, time horizon, financial situation, and risk tolerance of Clients. Under certain circumstances, BCM may work with Clients to develop a custom asset allocation.
• Portfolio Construction – BCM will develop and/or manage a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – BCM will provide investment management and ongoing oversight of the Client’s portfolio and overall account.
• Financial Planning and Consulting – using information and materials provided by the client, BCM will consult and strategize on recommendations and solutions regarding particular topics or concerns, and/or will produce a personalized financial plan that the client may use as supporting information in future financial activities and decisions. D. Wrap Fee Programs BCM does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by BCM. E. Assets Under Management As of December 31, 2023 - the most recent date for which such calculations are provided pursuant to securities regulations - BCM manages $125,467,386 in Discretionary Assets and $493,131 in Non-Discretionary Assets. Clients may request more current information at any time by contacting the Advisor.