Lexington Avenue Capital Management LLC was established in 2008 and became a registered Investment Advisor in 2013. The principal and sole owner of the firm is Larry Luxenberg. As of December 31, 2022, we manage client assets of $97,152,156 on a discretionary basis, and $7,974,278 on a non-discretionary basis for a total of $105,126,434 assets under management. In March 2022, Lexington Avenue Capital Management LLC filed its initial application to become registered as an investment adviser with the U.S. Securities Exchange Commission, which was accepted March 31, 2022. Investment Advisor Representatives of the Firm have education and business backgrounds that enable them to perform their respective responsibilities effectively. No formal, specific standards have been set, but appropriate education and experience are required. See the Form ADV, Part 2B Brochure Supplement for information about the Investment Representatives’ education and experience. Lexington Avenue Capital Management offers Portfolio Management Services for individuals, trusts and estates, small businesses, retirement plans, corporations, and non-profit organizations/foundations. We also offer financial planning and financial consulting services. We also offer pension consulting services to small business pension and profit-sharing plans, but only in the capacity as an ERISA 3(21) investment advisor. Asset Management Services We offer advisory services by providing investment advice and portfolio management services on a continuing basis, including the strategic allocation of managed assets among cash, stocks, and bonds with the selection of specific securities designed to provide proper diversification and help meet the client's investment objectives. Our investment philosophy is that long-term diversified managed portfolios is the strategy most likely to achieve long- term investment objectives. As a corollary, we have also concluded from years of experience and research by ourselves and others, including Nobel Prize laureates, that the client is not well-served by attempting to select individual stocks, timing those purchases and sales, and/or timing the market(s). We also consider the research done on behavioral investing to be very valuable in advising our clients. As appropriate for each client, our diversification strategy often includes low-fee passively managed mutual funds (and/or ETFs), with allocations across US, international, and emerging markets, in equities and/or fixed-income. Depending on the specific details of the client’s goals and circumstances, it may also include individual bonds and/or management of existing individual stocks, bonds and mutual funds/ETFs. We advise each client based on our understanding of their life circumstances, their financial situation, their life and investment goals, and their risk tolerance. These factors often go beyond the four corners of the client’s portfolio(s) and include such considerations as Social Security benefits, considerations of tax consequences, retirement goals, self- employment considerations, desires to care for adult children and/or grandchildren, etc. As a result, many of our client relationships are long-term and include the many stages and life events of our clients. Lexington tailors its advisory service to the individual needs of its clients. If a client wants to impose restrictions on their portfolio that is managed by us, we will discuss it with the client and reach a decision to either incorporate the restrictions into the portfolio, or segregate the non-recommended investments, and/or decline to continue an investment management relationship with the client, depending on the extent of the imposed restrictions and the circumstances. If a material conflict of interest arises between LACM and the Client, LACM will notify the Client of such potential conflicts of interest in writing. Retirement Plan Services Lexington Avenue Capital Management offers retirement plan services to retirement plan sponsors and to individual participants in retirement plans. For a corporate sponsor of a retirement plan, our retirement plan services can include, but are not limited to, the following services: Fiduciary Consulting Services Lexington Avenue Capital Management provides the following Fiduciary Retirement Plan Consulting Services:
• Non-Discretionary Investment Advice. Lexington Avenue Capital Management will provide you with general, non- discretionary investment advice regarding asset classes and investment options, consistent with your Plan’s investment policy statement.
• Individualized Participant Advice. Upon request, Lexington Avenue Capital Management will provide one-on-one advice to Plan participants regarding their individual situations and suggest suitable investment allocations within the Plan. For Fiduciary Consulting Services, all recommendations of investment options and portfolios will be submitted to you for your ultimate approval or rejection. For retirement plan Fiduciary Consulting Services, the retirement plan sponsor client or the plan participant who elects to implement any recommendations made by us is solely responsible for implementing all transactions. Fiduciary Consulting Services are not management services, and Lexington Avenue Capital Management does not serve as administrator or trustee of the plan. Lexington Avenue Capital Management does not act as custodian for any client account or have access to client funds or securities (with the exception of, some accounts, having written authorization from the client to deduct our fees). Lexington Avenue Capital

Management acknowledges that in performing the Fiduciary Consulting Services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. Lexington Avenue Capital Management will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause Lexington Avenue Capital Management to be a fiduciary as a matter of law. However, in providing the Fiduciary Consulting Services, Lexington Avenue Capital Management (a) has no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting management of Client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of Client’s retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of Client’s retirement plan or the interpretation of Client’s retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of Client’s retirement plan as defined in ERISA. Retirement Plan Rollover Recommendations When Lexington Avenue Capital Management provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to an IRA or make a distribution from the retirement plan account, we acknowledge that Lexington Avenue Capital Management is a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. The way Lexington Avenue Capital Management makes money creates conflicts with your interest so Lexington Avenue Capital Management operates under a special rule that requires Lexington Avenue Capital Management to act in your best interest and not put our interest ahead of you. Under this special rule’s provisions, Lexington Avenue Capital Management must act as a fiduciary to a retirement plan account or IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put the financial interests of Lexington Avenue Capital Management ahead of you when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that Lexington Avenue Capital Management gives advice that is in your best interest;
• Charge no more than is reasonable for the services of Lexington Avenue Capital Management; and
• Give Client basic information about conflicts of interest. To the extent we recommend you roll over your account from a current retirement plan account to an individual retirement account managed by Lexington Avenue Capital Management, please know that Lexington Avenue Capital Management and our investment adviser representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by Lexington Avenue Capital Management. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by Lexington Avenue Capital Management. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in Lexington Avenue Capital Management receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by Lexington Avenue Capital Management and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of Lexington Avenue Capital Management or our affiliated personnel. Lexington Avenue Capital Management does not participate in wrap fee programs.