A. Firm Information Bull Harbor Capital LLC (“BHC” or the “Adviser”) is a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”). BHC is organized as a Limited Liability Company (“LLC”) under the laws of the State of Maryland. BHC was founded in November 2022, and is owned by CRJ Financial Holding, LLC, L3RIA, LLC, T4G Management, LLC, Kenneth Brodkowitz (Chief Investment Officer), and Robert Herman (Chairman). Sean Joiner (President) owns CRJ Financial Holding, and Lloyd Polmateer (CEO) owns L3RIA, LLC, and T4G Management LLC is owned by the 4100 Group Inc. Candy Palugi is the Firm’s Chief Compliance Officer. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory business provided by BHC. Certain Investment Adviser Representatives (“IAR”) market and deliver advisory services under a practice name or “doing business as”, whose names and logos may appear on marketing materials as approved by BHC, or client statements approved by the custodian. It is important to note that, in certain cases, the businesses are legal entities of the IARs and are never legal entities of BHC or the custodian. However, the IARs are Independent Contractors with BHC and advisory services are provided exclusively through BHC. B. Advisory Business Offered BHC offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, charitable organizations, and retirement plans (each referred to as a “Client”). Investment Management Services BHC provides customized investment advisory solutions for its Clients. This is achieved through personal Client contact and interaction while providing continuous discretionary investment management and related advisory services. In certain instances, BHC may provide its services on a non-discretionary basis. As a discretionary investment adviser, BHC will have the authority to supervise and direct the portfolio without prior consultation with the Client. Clients who choose a non-discretionary arrangement must be contacted prior to the execution of any trade in the account(s) under management. This may result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non- discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio. BHC works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. BHC will then construct a portfolio utilizing mutual funds, exchange-traded funds (“ETFs”), individual public and/or private equity and fixed income securities. The Adviser may also utilize covered options and other types of investments, as appropriate, to meet the needs of a particular Client. BHC’s investment strategy is primarily long-term focused, but the Adviser may buy, sell, or re- allocate positions that have been held less than one year for reasons that include, but are not limited to: changes in Client objectives; account inflows/outflows; security fundamentals and/or market conditions. The first step of the BHC investment process is to determine the strategic asset allocation targets. Once BHC establishes the long-term framework, it’s determined if the Adviser should tactically adjust the allocation targets based on the current market environment and short- term economic outlook. BHC will construct, implement, and monitor the portfolio in connection with the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Adviser. BHC evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. BHC may recommend, on occasion, redistributing investment allocations to diversify the portfolio. BHC may recommend specific positions to increase sector or asset class weightings. The Adviser may recommend employing cash positions as a possible hedge against market movement. BHC may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. BHC will provide investment advisory services and portfolio management services and will not provide securities custodial or other administrative services. At no time will BHC accept or maintain custody of a Client’s funds or securities, except for authorized deduction of the Adviser’s fees. All Client assets will be managed within their designated account at the Custodian, pursuant to the terms of the investment advisory agreement. Portfolio Management accounts will be custodied at Fidelity (“Fidelity”) or Interactive Brokers (“IB”). Financial Planning Services BHC will typically provide a variety of financial planning services to Clients, pursuant to a written financial planning agreement. Services are offered in a variety of areas and are often tailored to the Client’s needs, goals, and financial situation. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to investment planning, retirement planning, personal savings, education savings and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence, or alter retirement savings, establish education savings and/or charitable giving programs. BHC may also refer Clients to an accountant, attorney, or another specialist, as appropriate for their unique situation. For certain financial planning engagements, the Adviser will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Adviser may not provide a written summary. Financial planning and consulting recommendations may pose a potential conflict between the interests of the Adviser and the interests of the Client. For example, a recommendation to engage the Adviser for investment management services or to increase the level of investment assets with the Adviser would pose a conflict, as it would increase the advisory fees paid to the Adviser. Clients are not obligated to implement any recommendations made by the Adviser or maintain an ongoing relationship with the Adviser. If the Client elects to act on any of the recommendations made by the Adviser, the Client is under no obligation to execute the transaction through the Adviser. Retirement Plan Advisory Services BHC provides non-discretionary retirement plan advisory services for retirement plans (each a “Plan”) and the sponsor of the Plan (the “Plan Sponsor”). The Adviser’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Support
• Investment Management
• Performance Reports
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services Certain of these services are provided by BHC serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of BHC‘s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Adviser reasonably expects under the engagement. Retirement Plan Rollover Recommendations To the extent we recommend you roll over your account from a current retirement plan to an individual retirement account (“Rollover IRA”), managed by BHC please know that BHC and our investment adviser representatives may 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 a Rollover IRA managed by BHC. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to a Rollover IRA managed by BHC. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to a Rollover 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 BHC receiving unreasonable compensation related to the rollover of funds from the retirement plan to a Rollover IRA, and (iii) fully disclose compensation received by BHC and all persons associated with BHC (our “Supervised Persons”) and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to a Rollover IRA and refrain from making any materially misleading statements regarding such rollover. When making a rollover recommendation BHC is serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). Use of Independent Managers BHC will at times recommend that Clients utilize one or more investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a client’s investment portfolio, based on the Client’s needs and objectives. Factors

that BHC considers in recommending/selecting Independent Managers generally include the Client’s stated investment objective(s), management style, performance, risk level, reputation, financial strength, reporting, pricing, and research. In certain instances, the Client will be required to authorize and enter into an investment management agreement with the Independent Manager(s) that defines the terms in which the Independent Manager(s) will provide its services. In other cases, BHC retains the authority to terminate the Independent Manager’s relationship or to add new Independent Managers without specific Client consent. In any case, the Firm will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Client’s investment objectives and overall best interest. BHC will also assist the Client in the development of the initial investment objectives and managing the ongoing Client relationship. The Client, prior to entering into an agreement with an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). Co-Advisory Arrangement with Matson Money, Inc. BHC has entered into a co-advisory agreement (the “Co-Advisory Agreement”) with Matson Money, Inc. (“Matson”), an SEC registered investment adviser. When appropriate and in accordance with a Client’s investment plan, BHC will recommend that the Client engage the co-advisory services of Matson and BHC. In such a situation, the Client, BHC, and Matson will enter into a tri-party investment management agreement (the “Investment Management Agreement”), pursuant to which BHC is responsible for selecting an appropriate and suitable investment model for the Client based on the Client’s investment objectives, risk tolerance, financial situation, time horizon, current investments, and financial goals. Matson is granted discretionary trading authority to invest the assets in the Client’s portfolio, which are typically invested in one or more series of the mutual fund RBB Fund, Inc., including the Free Market U.S. Equity Fund, Free Market International Equity Fund and Free Market Fixed-Income Fund (collectively, the “Matson Funds”). Each Matson Fund is a “fund of funds”, which invests primarily in shares of no-load mutual funds managed by Dimensional Fund Advisors (“DFA”) based on the investment characteristics specified by Matson and described in the Matson Funds prospectus. Each Matson Fund is designed to target specified percentages of certain asset classes in the Matson Fund’s applicable investment category to seek maximum portfolio diversification, enhanced return potential and diminished portfolio volatility. Matson reserves the right, in its sole discretion, to create and allocate assets in client accounts to additional funds managed by Matson in the future. Matson may also invest Client assets in unaffiliated cash sweep vehicles for temporary or other defensive purposes. More complete information is available in each applicable Matson Fund prospectus. In addition, BHC will provide certain ongoing advisory services to the Client in accordance with the Co-Advisory Agreement. The Client will have the authority to retain the co-advisory services of BHC and Matson and to terminate the Investment Management Agreement with BHC and Matson. IARs of BHC who wish to offer the tri-party Investment Management Agreement with Matson to their Clients and thereby participate in the Matson advisory program are required to pay a one- time fee to Matson in the amount of $10,000. The fee includes educational and training courses, some of which are required by Matson prior to permitting participation in the program. Matson also requires IARs to enter into tri-party Investment Management Agreements with Matson on behalf of BHC with respect to at least $100,000 of Client assets within the first year of participation in the program. If this minimum is not met, Matson reserves the right to terminate its relationship with the IAR, which may include terminating any Investment Management Agreements where such IAR is the signatory and requiring affected Clients to work with a different IAR. As the amount of assets managed pursuant to a tri-party Investment Management Agreement increases, the amount of marketing assistance provided to each applicable IAR increases, at no additional cost. Therefore, Phone: (301) 907-9030 http://www.bullharborcapital.com 76149965;3 BHC IARs who offer the Matson advisory programs have an incentive to select Matson over another program. BHC IARs will continue to review Client portfolio for program suitability and will retain responsibility for an annual review of Client accounts. Sub-Advisory Relationship with Gries Financial LLC BHC has entered into a sub-advisory agreement (the “Sub-Advisory Agreement”) with Gries Financial LLC (“Gries”), an SEC registered investment adviser under common control with BHC. Pursuant to the Sub-Advisory Agreement, BHC may be engaged by Gries to provide discretionary investment advisory services to certain portions of the portfolios of specified clients of Gries. BHC and Gries share a Chief Investment Officer, as further described below, and the Chairman of BHC is the CEO of Gries. BHC and Gries are also affiliated through TG4 Financial Services, LLC, which owns Gries and is a minority owner of BHC. Shared Services Agreement with Gries Financial LLC BHC also has a shared services agreement in place with Gries, an adviser under common control with BHC. When appropriate for a client, we will utilize Gries to provide personalized or model investment portfolios to our clients. When Gries Chief Investment Officer Services (“CIO Services”) are utilized by one of our Clients, the Client will pay a fee for these services up to a maximum of 15 basis points on the assets under management. This fee is in addition to our investment advisory fee. All fees are disclosed in the investment management agreement signed by the client. AssetMark, Inc. Platform Arrangements BHC has entered into two separate agreements with AssetMark, Inc. (“AssetMark”). AssetMark is an SEC registered investment adviser that has developed the AssetMark Platform (the “AssetMark Platform”). The AssetMark Platform consists of certain investment solutions and tools to help investment advisers provide advisory services to their clients. The two agreements that BHC has in place with AssetMark are: (i) a platform agreement, and (ii) a solicitation agreement. When appropriate and in accordance with a client’s investment plan, BHC will recommend that the client engage the services of AssetMark, as more specifically set forth below. Platform Agreement Under the platform agreement, BHC will utilize the AssetMark Platform to help manage the client’s assets. The AssetMark Platform contains various investment solutions, each of which includes one or more investment strategies. The investment solutions offered through the AssetMark Platform will generally be based on model portfolios or managed by discretionary managers. In addition, the AssetMark Platform provides certain administrative and other services, including, but not limited to, training and business consulting services, marketing support, preparation of individualized client materials, and the arrangement of custodial, brokerage, and related services on behalf of the client. In such a situation, the client will enter into a client services agreement (the “Client Services Agreement”) with BHC, pursuant to which BHC will be responsible for selecting an appropriate and suitable investment solution and investment strategy offered through the AssetMark Platform for the client based on the client’s investment objectives, risk tolerance, financial situation, time horizon, current investments, and financial goals. Under this arrangement, BHC is granted discretionary trading authority to invest the assets in the client’s portfolio pursuant to the selected investment solution and investment strategy offered through the AssetMark Platform. The total fee payable is set forth in the Client Services Agreement. Solicitation Agreement Under the solicitation agreement, BHC will recommend that a client engage the investment advisory services of AssetMark. In such a situation, the client will enter into an investment advisory agreement with AssetMark, and AssetMark will have discretionary trading authority to invest the assets in the client’s portfolio. However, BHC will provide certain ongoing services, including conducting an annual review of the client’s account to determine whether there have been any changes to a client’s financial situation or investment objectives and whether the client would like to impose reasonable restrictions on the management of his, her, or its assets and/or modify any existing conditions on such assets. In exchange for introducing the client to AssetMark and for the ongoing services provided by BHC, BHC receives initial and ongoing compensation from AssetMark. The amount of such compensation is negotiated by BHC and AssetMark in each case. The initial compensation is paid to BHC by AssetMark when contributions in excess of $2,000 are made to client accounts, and ongoing compensation is paid to BHC by AssetMark on the basis of the value of the client’s account. Additionally, BHC may receive additional fees from AssetMark depending on the investment solutions selected for a particular client. In such a case, the additional fee may be deducted from the client’s account by AssetMark and paid to BHC. C. Client Account Management Prior to engaging BHC to provide investment advisory services, each Client is required to enter into one or more agreements with the Adviser that define the terms, conditions, authority and responsibilities of the Adviser and the Client. These services may include:
• Establishing an Investment Strategy – BHC, together with the Client, will develop an investment strategy targeted to achieve the Client’s investment goals and objectives.
• Asset Allocation – BHC will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance of risk for each Client.
• Portfolio Construction – BHC will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – BHC will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Assets Under Management As of December 31, 2023, BHC has approximately $173,000,000 total assets under management. The Firm manages approximately $50,000,000 on a discretionary basis and $123,000,000 on a non-discretionary basis.