Sugar Maple Asset Management, LLC (the “Adviser”) began operations in January 2016 and is wholly- owned by Terry M. Jack and Jeremy P. Schwab. The Adviser is under common control with CAVU Capital Partners, LLC, discussed below. The Adviser’s services can be divided into the broad categories of Investment Management Services and Retirement Plan Services. The Adviser’s clients include high net worth individuals, pension and defined contribution plans, private funds, trusts, estates, charitable/non-profit entities, corporations and other business entities. All services are provided through the Adviser’s investment adviser representatives. Such investment adviser representatives are known as “Investment Managers” and are the primary client contact person for a given relationship. Services for clients vary by both individual client and the type of investment advice requested. A discussion of the various services offered follows. Investment Management Services Overview. The Adviser provides Investment Management Services which involve giving continuous advice to a client and making investments for a client based on the specific needs of the client. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, the Form ADV: Part 2A Page 3 Adviser can create and develop Investment Policy Statement (“IPS”) for the client and can use this to manage advisory accounts on a discretionary basis in a manner consistent with the client’s IPS. The Adviser will create a portfolio consisting of one or more of the following investments: individual stocks, bonds, mutual funds, exchange traded funds (“ETFs”), exchange traded notes and other collective investment vehicles. The Adviser will allocate the client’s assets among various investments taking into consideration the overall risk tolerance outlined by the client. The Adviser will select an investment based a variety of criteria, including, among other things: performance history and consistency of return (standard deviation); investment cost structure; tax considerations; management stability; industry sector allocation; market capitalization; investment style; and risk/volatility. Portfolio weighting will be determined by each client’s individual needs and circumstances, including cash flow needs, investment time horizon, IPS and risk tolerance. Clients have the opportunity to place reasonable restrictions or constraints on the way their accounts are managed and retain the right to modify account restrictions at any time by providing written notice of such changes to the Adviser. In addition, clients retain individual ownership of all securities held in their accounts. As a general rule, the Adviser believes that investing is most successful when investors take a longer-term view, defined as at least 5-7 years for more volatile investments such as stocks. Therefore, clients should not expect frequent investment changes in their portfolios, particularly in periods of extreme stock market volatility. Most investment changes will be made as a result of the following conditions: investment allocations that deviate from the client’s IPS; macro trends in the investment environment; investments that stray from original expectations; and, for collective investment vehicles such as mutual funds and ETFs, fundamental changes in investment vehicle structure, such as changing expense structure. The Adviser does not maintain custody of the assets in client accounts. Instead, all client assets are custodied with the client’s brokerage firm through which transactions are placed (the “Custodian”). The Adviser expects that in most cases, client’s will utilize Fidelity Investments as their Custodian. The Adviser does not assure or guarantee the results of its Investment Management Services; thus, losses can occur from following the Adviser’s advice pertaining to any investment or investment approach, including using conservative investment strategies. Use of Sub-Advisors. The Adviser can recommend the use of third-party investment advisers (“Sub- Advisors”) to manage all or a portion of the assets within a client’s account. Under these circumstances, the client would be required to enter into a separate investment management agreement with the Sub- Advisor, pursuant to which the Sub-Advisor would be granted discretion by the client to buy and sell securities for the client’s account. If a Sub-Advisor is used to manage client

assets, clients are encouraged to carefully review the Sub-Advisor’s Form ADV disclosure brochure, brochure supplement(s) and Form CRS (if applicable) for service level, fee, conflicts, and professional background information applicable to the Sub- Advisor’s staff before entering into the agreement. It is important to note that even though certain Sub-Advisors have achieved higher performance returns than others, they may not be recommended to a client by the Adviser due to the influence of other factors, such as the nature of a Sub-Advisor’s investment style and time under which securities were managed to produce returns. Thus, the Adviser can decide to select Sub-Advisors from a limited pool of firms based on objectives, manager experience, familiarity, costs, and performance, among other criteria. Once the Adviser recommends a Sub-Advisor to a client, the Adviser will periodically evaluate the Sub-Advisor’s performance and, if necessary, recommend a replacement Sub-Advisor when it is deemed necessary. The Adviser generally does not recommend the replacement of a Sub-Advisor based on short-term performance. Form ADV: Part 2A Page 4 In the event there is significant change in the Sub-Advisor’s investment philosophy, loss of significant investment management personnel or a change in ownership, the Adviser will re-evaluate the Sub-Advisor to determine whether to recommend a Sub-Advisor change to a client. Retirement Plan Services For retirement plan clients (each, a “Plan”), the Adviser offers a variety of Retirement Plan Services, including the following: 1. Assist the Plan client with the development of an IPS, along with investment guidelines and restrictions; 2. Identify specific investment options and/or third-party investment advisers within each asset category. At no time will the Adviser act as an “ERISA 3(38) Fiduciary.” Rather, the Adviser will act only as a non-discretionary co-fiduciary, pursuant to which the Adviser will provide investment recommendations to the Plan’s named fiduciaries, who will then be responsible for selecting the investment options from those recommendations; 3. Monitor and report the performance of all selected investment choices; 4. Recommend changes to the investment options; and 5. Review periodically the suitability of the Plan investment options. The Adviser also offers the following additional services to Plan clients: 1. Conduct periodic participant education and Plan-related meetings (live or web); 2. Assist with provider review and searches and negotiation of fees; and 3. Provide such other services as mutually agreed upon by the Adviser and the Plan client. Plan clients are free to contact their Investment Manager at any time, and to place restrictions on the types of securities the Adviser recommends for use by the Plan. The Adviser does not offer any service that guarantees a gain, or that a loss will not occur. All clients assume the risk that investment returns can be negative or below the rates of return achieved by other investment managers, market indices, or specific investments. Private Fund The Adviser serves as the investment adviser of a private hedge fund called the CAVU Private Opportunity Fund, LLC (the “Private Fund”). The Private Fund is available to certain qualified investors, and will be offered to qualified clients of the Adviser as deemed appropriate. The managing member of the Private Fund, CAVU Capital Partners, LLC (“Managing Member”), is under common control with the Adviser, and is therefore an affiliate of the Adviser. More information regarding the Private Fund, including, among other things, information regarding its investment program, risks, conflicts of interest, and fees, is available upon request. Form ADV: Part 2A Page 5 Other Services Financial Planning and Consulting. The Adviser offers financial planning and consulting services, which can include, among other things, assisting clients to: define their goals and priorities; establish clear milestones and financial planning objectives; organize their financial resources; analyze their situational risk factors to support better decision making; review their current estate plans; and assess their needs for different types of insurance. Assets Under Management As of December 31, 2022, Sugar Maple Asset Management managed $191.6 million in assets on a discretionary basis and $7.2 million on a non-discretionary basis.