Advisory Services PMV Capital Advisers, LLC (the “Adviser”) is an investment adviser providing investment management services to individuals, private pension and profit-sharing plans, trusts, estates, charitable organizations, corporations and business entities, and investment companies registered under the Investment Company Act of 1940 (each a “Fund”). Adviser’s services and fee arrangements are described in the following pages. Adviser is a limited liability company formed in 2020 under the laws of the State of Texas with its principal office location in Texas. The Adviser is wholly owned by PMV Capital, LLC. Through their ownership interests in PMV Capital, LLC, Daniel Snover, Mark DiGiannantonio, Andrew Nall, and James Leffler collectively own the Adviser. Typically, the Adviser manages client accounts through the use of models, employing its own proprietary investment strategies (each a “Model”). The Adviser’s Models are developed, largely, through the use of quantitative investment analysis regarding the market performance of various securities. The particular Model used for each client is based on the risk tolerance, investment objectives, and other criteria provided by the client to the Adviser. As these characteristics change over time, the Adviser may recommend that the Model be changed. Each Model consists of different weightings of various exchange traded funds and other securities. The Adviser shall buy, sell, exchange, and/or transfer shares of funds and other securities based upon the Model. The Adviser’s management has been designed to comply with the safe harbor provided under Rule 3a-4 of the Investment Company Act of 1940, as amended. Rule 3a-4 provides similarly-managed accounts, such as the investment strategy, with a safe harbor from the definition of an investment company. In accordance with Rule 3a-4, the following features have been specifically included in the Adviser’s management using the investment strategy: 1. Initial Interview – an initial interview is conducted with each client to determine the client’s financial circumstances, goals, acceptable levels of risk, any reasonable restrictions on the management of their account, and other relevant circumstances; 2. Individual Treatment – the client’s account is managed on the basis of the client’s financial circumstances and investment objectives; 3. Consultation – an Advisory Affiliate of the Adviser or the client’s representative knowledgeable about the client’s account shall be reasonably available to consult with the client relative to the status and management of their account; 4. Notice of Transactions – the client shall receive notice of all transactions in their account as if they had maintained a similar account outside of the investment strategy; 5. Quarterly Statement – the client shall be provided with a statement at least quarterly containing a description of all activity in their account; 6. Ability to Impose Restrictions – the client shall have the ability to impose reasonable restrictions on the management of their account, including the ability to instruct the Adviser not to purchase certain securities or types of securities; 7. No Pooling – the client’s beneficial interest in a security does not represent an undivided interest in all the securities held by the custodian, but rather represents a direct and beneficial interest in the securities which comprise the client’s account; 8. Separate Account – a separate account is maintained for the client with the custodian; and 9. Ownership - each client retains indicia of ownership of the account (e.g. right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations). In addition to the foregoing, clients may, in writing, place reasonable limitations upon the Adviser’s discretionary authority. The investment strategy may involve an above-average portfolio turnover that could negatively impact the net after-tax gain experienced by an individual client. Securities in the investment strategy are usually exchanged and/or transferred without regard to a client’s individual tax ramifications. Certain investment opportunities that become available to the Adviser’s clients may be limited. In order to meet its fiduciary duties to all its clients, the Adviser will endeavor to allocate investment opportunities among its clients on a fair and equitable basis. Adviser will have the power and authority, as granted by the client, to make investment decisions over the portion of the client’s assets managed by Adviser. Assets Under Management As of December

31, 2023, Adviser managed $78,991,427 of regulatory assets under management, as calculated for and reported in Item 5F of Part 1A of Form ADV, all on a discretionary basis. For purposes of calculating Regulatory Assets Under Management in Item 5F, Adviser includes Sponsored Investment Management Platform relationships where Adviser serves as a subadviser to other sponsoring investment advisers and for which Adviser provides continuous and regular supervisory or management services to such securities portfolios. Rollover Recommendations Retirement Plan Rollover Recommendations - When the Adviser 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 a IRA or make a distribution from the retirement plan account, we acknowledge that PMV Capital Advisers, LLC 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 PMV Capital Advisers, LLC is compensated creates conflicts with your interests so PMV Capital Advisers, LLC operates under a special rule that requires PMV Capital Advisers, LLC to act in your best interest and not put our interest ahead of you. Under this special rule’s provisions, PMV Capital Advisers, LLC must act as a fiduciary to a retirement plan account or IRA under ERISA/IRC and:
• Meet a professional standard of care when making investment recommendations (e.g., give prudent advice);
• Never put the financial interests of PMV Capital Advisers, LLC ahead of you when making recommendations (e.g., give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that PMV Capital Advisers, LLC gives advice that is in your best interest;
• Charge no more than is reasonable for the services of PMV Capital Advisers, LLC; and
• Give you basic information about conflicts of interest. To the extent PMV Capital Advisers, LLC recommend you roll over your account from a current retirement plan account to an individual retirement account managed by PMV Capital Advisers, LLC, please know that PMV Capital Advisers, LLC 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 PMV Capital Advisers, LLC. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by PMV Capital Advisers, LLC. 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 PMV Capital Advisers, LLC receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by PMV Capital Advisers, LLC 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 your regarding 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 PMV Capital Advisers, LLC or our affiliated personnel.