A. PVG Asset Management Corporation, a Colorado Corporation with its headquarters in Centennial, Colorado. PVG is a fee-based investment adviser specializing in money management services for individuals, corporations, registered investment advisers and institutions. The firm was established in 1988. The primary owner of PVG, a C-Corp, is Patrick Adams. B. As an asset manager, any financial advice provided is incidental to asset management services. PVG does not provide financial planning, offer tax advice, insurance or other wealth management services unless specifically stated in a signed agreement specifying such services and the fees for these additional services. Typically, an asset management client selects a specific strategy displayed on a PVG investment advisory agreement. Clients may change strategies upon notification to firm. PVG clients may opt to invest in individual stocks and bonds, or Exchange Traded Funds (ETFs). Our overall asset management approach is characterized as “Loss Averse Investing” to emphasize that loss aversion is a primary investment objective, in contrast to tracking market or peer-based indices. PVG’s loss averse strategies hedge against the possibility of weak markets by moving in and out of equities, fixed income, or by buying inverse ETFs. Advisory clients may also direct PVG to purchase, sell or hold individual investment products of their choice rather than participate in the “Adverse Investing” strategies. In such cases, PVG does not accept responsibility for client choices. PVG does provide strategies where those assets move more or less like the overall markets, or traditional strategies. C. PVG does not guarantee against investment losses. Investing in securities involves risk of loss that clients should be prepared to bear regardless of the strategy being loss averse. D. Besides the individual accounts of clients with a PVG agreement, the firm manages accounts under sub-contract with other investment advisors. In such cases, PVG shares a portion of the total management fee paid to the other investment advisor. In these circumstances, the other investment advisor maintains the primary client relationship. PVG only manages the assets based upon the parameters provided by that investment advisor and does not share responsibility for any client communication, on-going review of the client’s risk profile and appropriateness of investment strategies for that client. E. PVG’s Investment Advisory agreements may include a risk questionnaire which attempts to measure the risk tolerance acceptable to the potential client so that we more accurately direct them to the appropriate PVG investment strategy. Because client risk appropriateness is very subjective and client’s often change their perception of risk as markets evolve, PVG makes no claim that its risk profile questionnaire can accurately capture any client’s future perception of risk. In addition, the riskiness of assets often changes significantly under unusual circumstances or market conditions. F. Some Investment Advisor Reps (IARs), who have an association with PVG, may offer wealth management services including asset management, asset allocation, and other services which may encompass third party money managers, firms, and service providers not affiliated with PVG. This may involve the review of client’s legal, accounting, insurance, other professional advisors and other services. These IAR’s or other third-party service providers may have ancillary agreements and fees for these services which may be in addition to PVG money management or advisor services fees, although these fees may be included in a WRAP structure payable to PVG where the client generally pays a single fee for all services. For instance, such additional fees may include an advisory fee for the allocation service, a separate fee to PVG for portfolio management, or additional fees to outside managers and other entities. Any ancillary agreement, other than a PVG Asset Management Agreement

provided by an IAR must specify the services and fees charged and document whether PVG is monitoring and compensated for any specific asset management or other service. PVG accepts no responsibility for any assets or services which it is not monitoring or for which it is not compensated. As with all investing, these other assets and services can cause client losses for many different reasons. Through agreement with PVG, IARs with a PVG association may use their individual legal business names and logos on PVG marketing materials and/or client statements, including titling such as PVG Asset Management, Company, dba as “the name of their own business entity”. All public advertising produced by these entities is reviewed by PVG and must read “Advisory Services offered through PVG Asset Management Corporation, a SEC registered Investment Adviser. Registration with PVG Asset Management does not imply any level of skill or training of the IAR, nor that PVG has provided any due diligence or approval of their outside services and products IAR’s associated with PVG as separate business entities must disclose the extent and limit of their association with PVG to clients and potential clients. G. PVG does not monitor investments of the client that PVG does not directly manage, or monitor, under its advisory agreement for a fee stated in paragraph D above. If an investment or service is not identified as a PVG strategy or service in and including a PVG investment advisory agreement of PVG, and PVG is not receiving or retaining any fee for that service, PVG does not accept responsibility for that product or service, regardless of any PVG IAR affiliation, even though we may include those asset(s) or services on client statements for informational purposes. H. PVG may provide customized investment management services that include restrictions on the purchase or sale of certain securities, within the boundaries of our Loss Averse Investing strategies or individual client directives for specific product prohibitions. PVG is not responsible for restricted positions in a client account, including stocks, bonds, REITs, hedge funds, private placements and any other type of registered or non- registered security that is not specifically part of a PVG strategy. When such unmanaged positions appear on a PVG statement or a custodial statement it is for the benefit of the client and not the responsibility of PVG, regardless of fee structure. I. Clients may make additions to and withdrawals from their account at any time, subject to PVGs’ right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or declines to accept particular securities into a client’s account. Clients may withdraw account assets on notice to PVG, subject to the usual and customary securities settlement procedures. However, the Firm generally designs its portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a client’s investment objectives. PVG may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, and short-term redemption or other fees, that may be assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications. J. Clients generally provide PVG with the authority to directly debit their accounts for payment of the investment advisory and other transaction related fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to PVG. K. As of 3/8/2024, PVG had 422 total accounts with $500,377,000 of assets under management. 421 discretionary accounts with $301,377,000 and 1 non- discretionary account with $199,000,000 in assets.