Firm Description O’Dell Capital Management ( “OCM” or the “Firm”) is an SEC-registered investment advisor. OCM was founded on February 10, 2009, and began operating as a Registered Investment Advisor in 2023. The Principal Owner of OCM is Rick C. O’Dell, and Chief Compliance Officer of OCM is Denise Young. Types of Advisory Services The Firm offers a large variety of services, including portfolio management, investment analysis and financial planning, retirement planning, and financial planning-focused estate planning for individuals and high net worth individuals. The Firm offers these services to clients or potential clients (“Clients” or “Client”). Investment Advisory Services OCM specializes in quantitative, fundamental, technical, and economic analysis to determine what investments are in favor of OCM’s investment models. OCM assesses clients ’current holdings and ensures alignment with both short- and long-term goals. The Firm performs ongoing reviews of investment performance and portfolio exposure to market conditions. Accordingly, the Firm is authorized to perform various functions without further approval from the client under a discretionary agreement, such as the determination of securities to be purchased or sold without prior permission from the client for each transaction. OCM also offers a non-discretionary arrangement, under which the same services are offered, but OCM must seek explicit approval from the client to purchase or sell securities. Any and all trades are made in the best interest of the client as part of OCM’s fiduciary duty. However, risk is inherent to any investing strategy and model. Therefore, OCM does not guarantee any results or returns. Prior to engaging OCM to provide any investment advisory services, OCM requires a written financial service agreement (“FSA”) signed by the client prior to the engagement of any services. The FSA will outline services to which the client is entitled and fees the client will incur. OCM maintains and utilizes six investment models to serve its clients’ goals. Client assets will be placed in a particular model to be determined by a particular client’s investment profile. The models to be utilized are as follows: 1. Lodestar Conservative 2. Lodestar Conservative Balanced 3. Lodestar Balanced 4. Lodestar Balanced Growth 5. Lodestar Growth 6. Lodestar Aggressive Growth These models are listed in order from most to least conservative. OCM is an asset-based fee investment management firm. The firm does not receive commissions for purchasing or selling stocks, bonds, mutual funds, real estate investment trusts, or other commissioned products for clients. The firm is not affiliated with entities that sell financial products or securities. No commissions in any form are accepted. OCM does not act as a custodian of client assets. The client always maintains asset control. OCM places trades for clients under a limited power of attorney through qualified custodian/broker. Retirement Plan Services: OCM works with Plan Sponsors to provide investment advisory and consulting services plans per the terms and conditions of a Retirement Plan Consulting Agreement between OCM and the plan. Portfolio management clients paying management fees will receive these services

free of charge. For such engagements, OCM assists Sponsors of retirement plans with the selection and/or monitoring of investment alternatives (generally open-end mutual funds) from which plan participants can choose in self-directing the investments for their individual plan retirement accounts. In addition, to the extent requested by the Plan Sponsor, OCM may also provide participant education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. In engagements, OCM will serve as an investment adviser/fiduciary as those terms are defined under Sections 3(21) of the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended. Financial Planning & Consulting Services: OCM offers standalone financial planning and consulting services for a negotiable fee. Portfolio management clients paying management fees will receive these services free of charge. Financial Planning and Consulting services typically include investment and non-investment matters, business succession planning, estate planning, and family meetings. To engage in financial planning and consulting services, clients enter into an engagement that sets the terms of the engagement, scope of services, and the negotiated fee. When requested by the client, OCM may recommend third parties to assist in implementation. The client retains discretion over implementation decisions and is free to accept or reject any recommendation of the Firm. It is the client’s responsibility to notify the Firm of changes to financial situations and objectives. Services Tailored to Clients’ Needs Services are provided based on a client’s specific needs within the scope of the services provided as discussed above. A review of the information provided by the client regarding the client’s current financial situation, goals, and risk tolerances will be performed and advice will be provided that is in line with available information. OCM utilizes Goal Planning and Monitoring technology to assess client’s individual and unique objectives. The information gathered is used in recommending the appropriate investment model (allocation). Simulation software is used to guide towards the allocation with the highest probability of success. Clients may impose restrictions on investing in certain types of securities. OCM manages six investment models under the Lodestar title (Lodestar Conservative, Lodestar Conservative Balanced, Lodestar Balanced, Lodestar Balanced Growth, Lodestar Growth and Lodestar Aggressive/All Equity), as discussed above. Each model contains mutual funds and/or ETFs to provide broad diversification in the areas of U.S. Stocks, International Stocks and U.S. Aggregate Bonds. OCM also manages an all equity, limited holdings model for clients who prefer individual stocks. This model (Lodestar Earnings and Profitability) focuses on 25-50 securities chosen for past earnings and profitability record. Wrap Fee Program versus Portfolio Management Program OCM does not offer a Wrap Fee Program. Assets Under Management As of July 62023, Adviser has the following assets under management: Discretionary assets: $101,017,545 Non-discretionary assets: $20,397,800