Description of Services and Fees Shellman Investment Management, LLC (hereinafter “Shellman Invest”) is a registered investment adviser based in Miami, Florida. We are a limited liability company, formed under the laws of the State of Delaware. Stephanie Lynn Shellman, CFA is Chief Executive Officer and sole owner and Rajiv Shah is the Chief Compliance Officer of Shellman Invest. You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to anyone from our firm who is an officer, employee, and all individuals providing investment advice on behalf of our firm. Such persons are properly registered as investment adviser representatives in applicable jurisdictions where required. Portfolio Management Services Our firm provides discretionary and non-discretionary portfolio management services to clients, some of which are referred by our related company Shellman S.A. (DBA Shellman Wealth), a duly registered Portfolio Manager located in Montevideo Uruguay. Shellman Invest uses model portfolios to invest client funds. The portfolio development process has two steps. First, we create 8-10 strategic asset allocations with different levels of projected long-term Return and volatility levels using Long Term Capital Market Expectations provided by JP Morgan. The information is summarized in an Investor Profile which is signed by the client and defines the asset allocation to be used. To implement the asset allocation strategy, Shellman Invest uses mutual funds,

exchange traded funds and international investment company security equivalents in its portfolio management program. We analyze the mutual fund and ETFs universe offered by each broker and chose each instrument per asset class. In mutual fund or ETF determination, we take into account asset class fit, all in cost, historical performance, qualitative factors such as process and people and independent Research Reports from suppliers such as Morningstar. Discretionary portfolio management means we will make investment decisions and place buy or sell orders for your account without contacting you. We make our decisions upon the Investor Profile signed by you and provided to us by you. Additionally, we will provide advice on existing investments you may hold at the inception of the advisory relationship or on other types of investments for which you ask advice. Non-discretionary portfolio management means we will seek your approval before any buy or sell orders are placed on your account, and you will have the ultimate decision on any investments. We monitor each portfolio’s performance on a continuous basis, and rebalance the portfolio whenever necessary, as changes occur in market conditions and/or your financial circumstances. Wrap Fee Programs We do not sponsor, manage, or participate in any wrap fee programs. Assets Under Management As of December 31, 2023, Shellman Invest maintained $139,445,177 in assets under management managed on a discretionary and non-discretionary basis.