Firm Description Corundum Group, Inc. (“CG”) was founded in 1992 and operated as a family office. At the start, nearly all assets under management were from descendants of a single family. As it grew, CG gained numerous other high-net- worth clients. The office is located in Colorado Springs, CO. CG is a Registered Investment Advisor with the SEC that provides investment advisory services and manages investment accounts for individuals, high-net-worth individuals, trusts, foundations, and partnerships. Advice is provided through consultation with the client and may include determining financial objectives, identifying financial problems, cash flow management, tax planning, estate planning, retirement planning, insurance review, and education funding. CG provides its clients with access to a range of equity investment classes and styles, including large-cap growth and value, small and midcap growth and value, and international stocks. Other investments, such as fixed income, debt funds, real estate, and private equity, are also offered to clients. Most clients have given CG discretionary authority to buy and sell investments on their behalf. Principal Owners CG is a wholly owned subsidiary of Corundum Holdings, Inc. Ron Johnson is the Founder and primary shareholder of Corundum Holdings, Inc. Types of Advisory Services Asset Allocation: CG meets with clients to establish investment goals, risk tolerance, and income needs. From its broad asset allocation choices, CG creates a target allocation for each client, which is periodically compared to the actual allocation. Investment Management: A large portion of assets under management are invested in Private Funds. These Private Funds can be managed by either CG or its affiliate, Corundum Partners, Inc. In some cases, the investments inside these Private Funds are managed by third-party investment managers. Some of the funds invest in specific strategies and allow some control over taxable realized gains. Other funds are vehicles for investing in alternative private investments, including proprietary products. Mutual funds and individual securities can also be held in separately managed brokerage accounts.

The brokerage firm does not typically charge a fee for stock and bond trades but does charge a transaction or an asset-based fee for its services as a broker-dealer, such as sub-advisory and custody (see Item 12: Brokerage Practices). Federal, state, and agency fees may apply. CG does not receive compensation from mutual fund companies. Estate Planning: CG advises interested clients on a wide range of estate planning techniques. These techniques may include Revocable and Irrevocable Trusts, Grantor-Retained Annuity Trusts, Charitable Lead Annuity Trusts, Charitable Remainder Unitrusts, Irrevocable Life Insurance Trusts, Limited Partnerships, or other currently appropriate planning techniques. Tailored Relationships The goals and objectives for each client are documented, and an Advisory Services Agreement is executed that explains the services we provide and our fees. A Statement of Investment Objectives is created to reflect the risk tolerance, time horizon, and investment objectives of each client. We provide quarterly reports and meet with clients as needed. Clients may impose restrictions on investing in certain types of securities. Allocation of investment opportunities will not be uniform among clients. Not all investments are suitable for all clients due to clients’ varying investment objectives, risk tolerance, and eligibility. Although clients with smaller account balances often participate in investment opportunities made possible by larger CG clients, not all investments will be offered or offered proportionally to all clients. Assets under Management As of December 31, 2023, CG manages approximately $1,407,752,246 in client assets, of which approximately $1,402,055,122 is managed on a discretionary basis, and $5,697,124 is managed on a non-discretionary basis. Assets under Advisement An asset under advisement (“AUA”) calculation includes all assets that an advisor advises on and may include non- securities such as real estate, loans, and other income-producing properties, as examples. AUA will be reported based on the asset's current known values as of the reporting date. As of December 31, 2023, CG has approximately $2,215,507,367 in AUA.