A. Description of Firm First Wilshire provides discretionary investment management services to separately managed accounts (“SMA” or “SMAs”) established by individuals, pension and profit-sharing plans, charitable organizations, corporations and other institutions. We also manage two affiliated private funds. Apart from custom portfolios, for most SMAs, we invest primarily in equity securities using a value and contrarian investment philosophy consisting predominantly, though not exclusively, of small and micro-cap U.S. and foreign equity securities. Foreign securities include but are not limited to ordinary shares, depository receipts including American Depositary Receipts (“ADRs”), American Depositary Shares (“ADS’”) and Global Depository Receipts (“GDRs”), or warrants. Such securities will be traded via the New York Stock Exchange, NASDAQ, the American Stock Exchange, OTCBB, the Pink Sheets, and in other exchanges or venues. First Wilshire does not generally tailor our SMA investment strategy and small-cap investment style to the individual needs of Clients. This strategy also is not specifically tied to traditional benchmarks. Please refer to Item 8 below for important information related to our Methods of Analysis and Risk of Loss. B. Type of Advisory Services we Offer First Wilshire provides three types of advisory services: SMA Investment Management Services, Custom Portfolio Management, and Financial Review Services, all of which are more fully described below. 1. SMA Investment Management Services For SMA Clients, First Wilshire does not generally tailor our investment strategy and small-cap investment style to the individual needs of those Clients, meaning that Clients may not generally impose restrictions requiring us to invest in certain securities or types of securities that we believe would hinder our management of the portfolio. However, under certain circumstances we reserve the right to accommodate reasonable restrictions on investing in certain securities, types of securities, or industry sectors. First Wilshire currently offers only fee-based SMA advisory services (See Item 5 for a description of services and fees). 2. Custom Portfolio Management For Clients who require Custom Portfolio Management, First Wilshire

will customize Clients’ portfolios according to their individual risk tolerance, time horizon and specific goals. Generally, First Wilshire will design an investment strategy unique to each individual to meet their objectives (although most strategies tend to be aggressive). Each Client’s portfolio is traded and rebalanced on an as-needed basis in accordance with the strategy selected. Generally, First Wilshire invests Client assets based on tactical allocation1, taking into consideration the Client’s unique needs and circumstances. 3. Financial Review Services First Wilshire’s Financial Review Services provide our Clients with an analysis of the steps Clients may wish to consider within their investment portfolio to help achieve their financial goals and objectives. To begin this process, First Wilshire generally will interview the Client to gather certain necessary information to assess the Client's current financial situation. Based upon this initial interview, First Wilshire may ask the Client to provide First Wilshire with all necessary documentation in order to assess the Client’s current and anticipated investment positions and financial objectives. The Client has full discretion to accept, reject or modify the results of First Wilshire’s review. At all times, First Wilshire will rely upon the information provided by our Clients so it is important for each Client to provide accurate, updated and complete information to us. C. General Information Prior to engaging First Wilshire to provide any advisory services, the Client is required to enter into an Investment Management Agreement with the Firm setting forth the terms and conditions of the engagement, as well as describing the specific scope of services to be provided. As noted above, we managed the assets of two affiliated private funds that are managed differently than the SMAs. See Item 6 for a further description. First Wilshire had approximately $328,779,338 of Client assets under discretionary management as of December 31, 2023. 1 Tactical allocation is an investment style in which the three primary asset classes (stocks, bonds and cash) are actively balanced and adjusted. The main goal of tactical allocation is to maximize portfolio returns while managing market risk.