A. Description of the Advisory Firm Roosevelt Capital Management LLC (hereinafter “RCM”, previously White Lake Capital Management LLC) is a Limited Liability Company organized in the State of Texas. The firm was formed in February 2016, began conducting business in March 2019, and the owners are David Anthony Roosevelt, Roosevelt Investments, LP and Michael Patrick O’Brien. The General Partner of Roosevelt Investments, LP is Roosevelt Investments Management, LLC, and Roosevelt Investments, LP is principally owned by RI Residual, LP. B. Types of Advisory Services Portfolio Management Services RCM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Prior to providing advisory services to a client, RCM and the client shall complete and execute an investment management agreement outlining the services to be provided, the terms of the services as well as an investment policy statement. The firm will only use an investment management agreement that has been reviewed and approved by the CCO. The firm will generally require new clients to fill out a “New Client Information Form” if, and only if, the client claims not to be a High Net Worth individual. However, RCM may make exceptions on a case-by-case basis. RCM evaluates the current investments of each client with respect to their risk tolerance levels. RCM will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. RCM seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of RCM’s economic, investment or other financial interests. To meet its fiduciary obligations, RCM attempts to avoid, among other things, investment or trading practices that systematically advantage or

disadvantage certain client portfolios, and accordingly, RCM’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is RCM’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Types of Advisory Services and Services RCM generally offers client U.S and non-U.S. fixed income securities, equities and cash management, but may use other securities as well to help diversify a portfolio when applicable. Please see Item 8 for more information regarding risks of certain products. C. Client Tailored Services and Client Imposed Restrictions Depending on client needs, RCM may tailor an individualized program, or it may implement the firm’s investing strategy designed to accommodate any of our clients. RCM may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. RCM constructs portfolio guidelines which may include but are not limited to investment objective, allowable investments, credit quality, maturity / duration, liquidity, and issuer concentration. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent RCM from properly servicing the client account, or if the restrictions would require RCM to deviate from its suite of services, RCM reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. RCM does not participate in wrap fee programs. E. Assets Under Management RCM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 198,663,696 $ 0.00 March 2023