Item 5 – Additional Compensation ...................................................................................................................... 16 Item 6 – Supervision .............................................................................................................................................. 16 Item 7 – Requirements for State-Registered Advisers ....................................................................................... 16 LIMC is an independent investment counseling firm founded in 1981 by Gregory C. Lathrop. Mr. Lathrop is the sole owner of LIMC. Our current professional investment team includes Gregory C. Lathrop, Andrew A. LaGrone, J. Wesley Havens, and Ryan M. Gattin. LIMC provides discretionary investment counseling to individuals, families, trusts, estates, retirement plans, businesses and not-for-profit institutions. We maintain separately managed accounts for all clients. These separate accounts are maintained at various independent and client-directed custodians, none of which is affiliated with us. Typically, the custodian is a major national brokerage firm or bank trust company. Our clients are billed for services rendered based on a percentage of those assets under our management. See Item 5 for fee schedule details. We also provide manager-of-managers investment services for one client where we manage asset mix relative to the clients’ investment objectives and manage unaffiliated investment advisors and custodians. We have one relationship that is considered assets under advisement. LIMC primarily utilizes individual stocks, bonds and cash to construct client portfolios. The companies whose stocks we invest in are typically headquartered in the United States though, in aggregate, these companies typically have a third or more of their operations focused on foreign markets, which gives LIMC stock portfolios meaningful exposure to both the domestic and global economies. We utilize high-quality corporate, municipal and U.S. government treasury and agency bonds, FDIC-insured bank certificates of deposit and money market funds

to manage our clients’ cash flow, liquidity and tax efficiency objectives. We use exchange-traded funds (“ETF”) primarily when a client portfolio does not have sufficient size to be properly diversified with individual securities. We are aware that any individual client may have unique needs regarding their investment management. We are capable of tailoring portfolios to those individual needs in most situations. Clients may impose restrictions on investment in certain specific securities or types of securities. For example, they might restrict our selling a concentrated legacy holding, may direct that we only invest in fixed income securities or may prohibit us from using specific securities. When LIMC provides investment advice to a client regarding the client’s retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way LIMC makes money creates some conflicts with client interests, so it operates under a special rule that requires it to act in the client’s best interest and not to put its interest ahead of the client’s. Under this special rule’s provisions, LIMC must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put its financial interest ahead of the client’s when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that LIMC gives advice that is in the client’s best interest;
• Charge no more than is reasonable for LIMC’s services; and
• Give the client basic information about conflicts of interest. As of December 31, 2023, LIMC managed $868 million of client assets for approximately 226 client relationships composing 841 individual investment accounts. These totals included $188 million in funds where LIMC acts as a manager of other investment managers for one client relationship comprised of one individual investment account. Additionally, LIMC has a relationship with one account totaling $18.1 million that is considered assets under advisement. This total is not included in regulatory assets under management.