Firm Description Excel Capital Management Corp. (“ECM”), a Registered Investment Adviser, was founded in 2000. ECM provides personalized confidential investment management to individuals, trusts, small businesses and corporations. Advice is provided through initial and periodic consultation with the client and may include: determination of financial objectives, cash flow management, tax planning, investment management, education funding, retirement planning, and estate planning. ECM provides portfolio management through buying and selling of stocks, bonds, warrants, exchange traded funds (ETFs), mutual funds, options on behalf our clients. ECM does not act as a custodian of client assets. The client always maintains asset control. Fidelity Investments provides Custody, Clearing & Brokerage services. ECM places trades for clients under a limited power of attorney without discussing the transactions in advance. Client receives a monthly Account statement from the custodian which includes portfolio holdings and a summary of transactions. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. The initial meeting, which may be by telephone, is free of charge and is considered an exploratory interview to determine the extent to which investment management may be beneficial to the client. Principal Owners Pradeep Niphadkar, PhD is the principal owner. Types of Advisory Services EMC provides investment supervisory services, also known as asset management services. As of December 31, 2023, ECM managed approximately $148,841,000 in assets for approximately 62 clients. As of March 26,2024, ECM managed approximately $162,850,000 in assets for approximately 65 clients. All of these assets are managed on a discretionary basis. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system. Investment policy statements are created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Types of Agreements The following agreements define the typical client relationships. Financial Planning Agreement Not Applicable. Advisory Service Agreement Most clients choose to have EMC provide discretionary portfolio management on a continuous basis. All aspects of the client’s financial affairs are reviewed. Realistic and measurable goals are set and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The scope of work and fee for an Advisory Service Agreement or also known as Investment Management Agreement is provided to the client in writing prior to the start of the relationship. An Advisory Service Agreement includes investment management (including performance reporting. The Advisory Service Agreement quarterly

fee is based on a percentage of the investable assets according to the following schedule: Assets Quarterly Fees $6 Mil & above 0.1875% $5 Mil -6 Mil 0.20% $4 Mil-5 Mil 0.2125% $3 Mil-4 Mil 0.225% $1 Mil-3 Mil 0.25% $500K-999K 0.3125% $200K-499K 0.375% 0-199K 0.5% The minimum annual fee for managing $500,000 portfolio is $6,250 and is not negotiable. Current client relationships may exist where the fees are higher or lower than the fee schedule above. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. At termination, fees will be billed on a pro rata basis for the portion of the quarter completed. The portfolio value at the completion of the prior full billing quarter is used as the basis for the fee computation, adjusted for the number of days during the billing quarter prior to termination. Any prepaid fees will be prorated and the unused portion will be returned to the client. Retainer Agreement Not Applicable. Investment Management Agreement An Investment Management Agreement also known as Advisory Service Agreement is executed as a part of the relationship. By this agreement, client retains ECM as “adviser” to provide investment advisory services. The annual fee for an Investment Management Agreement is based on a percentage of the investable assets. The minimum annual fee for managing $500,000 is $6,250 and is not negotiable. Tax Preparation Agreement Not applicable. Hourly Planning Engagements Not Applicable. Asset Management Assets are invested primarily in exchange-traded funds, no-load or low-load mutual funds and, usually through discount brokers or fund companies. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Discount brokerage firm may charge a small transaction fee for the purchase of some funds. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The brokerage firm charges a fee for stock and bond trades. ECM does not receive any compensation, in any form, from fund companies. Investments may also include: equities (stocks), warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (mutual funds shares), U. S. government securities, options contracts. Participation in Initial public offerings (IPOs) is available through ECM upon request. Termination of Agreement A Client may terminate any of the aforementioned agreements at any time by notifying ECM in writing and paying the rate for the time spent on the investment advisory engagement prior to notification of termination. If the client made an advance payment, ECM will refund any unearned portion of the advance payment. ECM may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, ECM will refund any unearned portion of the advance payment.