formed in California in 1972 to provide investment management services for individuals (retirement and non-retirement accounts), high net worth individuals, individual pension and profit sharing plans, trusts, estates or charitable organizations, corporations and limited liability companies and small institutions. We provide investment supervisory services on a discretionary basis. We seek to invest in securities with high growth rates and potential for long term capital appreciation. The firm specializes in the management of equity and balanced asset portfolios for capital appreciation in the domestic and international markets. The firm is registered with the Securities and Exchange Commission under the Investment Advisors Act of 1940. In addition, Robert Bender & Associates is a member of the Investment Counselors Association of America (ICAA), a professional association. As of December 31, 2023, the firm’s Assets Under Management (“AUM”) was approximately $409.7. For purposes of calculating the firm’s AUM, we include all assets in all accounts, including cash positions. Investment Philosophy. The foundation of our investment philosophy is a commitment to capital appreciation well in excess of economic and general market growth, while limiting exposure to fundamental risk. We achieve this by following a disciplined approach to investing in high-quality sustainable growth companies. Termination. Investment Advisory contracts may be terminated at any time by either party by giving notice of such termination in accordance with the terms of the Investment Advisory Client Agreement to the other party which must be confirmed in writing. In addition, clients entering into an Investment Advisory Client Agreement will receive a copy of this Form ADV Part 2, and, beginning

June 30, 2020, a copy of its ADV Form CRS at the time the client enters into the Agreement. Any prepaid fees under such Agreement are prorated for the period and any unearned fees are returned to the client upon termination. Investment Professionals. The Investment Committee of Robert Bender & Associates consists of the two investment professionals, Robert L. Bender and Reed G. Bender. The education and background of the firm’s professionals is as follows: Robert L. Bender (date of birth: May 28, 1937) Education: BA, Economics, University of Redlands MBA, Finance, Graduate School of Management at University of California at Los Angeles Past 5 Years: Chairman of the Board, Robert Bender & Associates Reed G. Bender (date of birth: May 18, 1968) Education: BA, Communications, University of the Pacific Past 5 Years: President, Chief Investment Officer, Robert Bender & Associates Robert Bender & Associates  Part 2A of Form ADV  March 2024 Page 2 In addition, the firm has “Newsletter/Impersonal Advisory Services” relationships with the following firm and individuals: (1) RBA Client Services, 15 South Raymond Avenue, Suite 200, Pasadena, CA 91105; telephone: (626) 844-1441; facsimile: (626) 440-1319 The principal of RBA Client Services and his educational and background information are as follows: John Patrick Odell (date of birth: March 22, 1966) Education: BBA Finance, University of Notre Dame Position: Independent Marketing Agent (2) James Patrick Huang, Post Office Box 8535, Rowland Heights, CA 91748; telephone: (949) 295-3777 His educational and background information are as follows: James Patrick Huang (date of birth: February 12, 1963) Education: University of Southern California Position: Independent Marketing Agent