Separate Account I nvestment Management Services Ardent Capital Management, Inc. was first established in 1993 as Chartwell Advisors. Chartwell Advisors transitioned to Winston Advisors, Inc., then Winston Investment Management, Inc., and later becoming Ardent Capital Management, Inc. Ardent provides discretionary investment management services to clients. The firm was founded by Charles A. and Christopher J. Donabedian. After developing a client's personal investment objectives through discussions about goals and objectives, risk tolerance, income needs, liquidity needs and tax considerations, a written investment advisory agreement is executed between the client and Ardent. All client accounts will be managed in accordance with their respective investment objectives.
Portfolios may consist of one or more of the following securities:
•equities, both common and preferred
•U.S. government securities, municipal and corporate debt
•options and warrants
•certificates of deposit,
•mutual funds.
•Any other securities appropriate and consistent with the client goals, risk tolerance and objectives. Ardent Capital Management, Inc. manages two accounts on a non-discretionary basis. One of those accounts holds a concentration of one or more securities in which Ardent Capital Management, Inc. employs a derivative overlay strategy to optimize income and returns. The fees for these non- discretionary services are negotiable.
We offer advice on equity securities, warrants, corporate debt securities (other than commercial paper), commercial paper, certificates of deposit, municipal securities, variable life insurance, variable annuities, and United States government securities. We may invest in mutual funds that use alternative strategies that utilize futures or options on futures. Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
Private Fund We serve as Investment Manager to the ACM Opportunity Fund LLC (the "Fund"), which seeks long- term growth of capital via both income and capital gains. By

the nature of the assets in which it invests, the Fund is aggressive in its orientation and will experience volatility in the price of underlying securities. Investment in the Fund is only offered to a limited number of accredited investors via a Private Offering Memorandum. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you.
4 When we provide investment advice to you regarding your 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 we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Assets Under Management As of December 31, 2023, we provide continuous management services for $247,089,746 in client assets on a discretionary basis, and $46,959,725 in client assets on a non-discretionary basis.