Firm Background Commonwealth Investment Management (“CIM”) is an SEC registered investment adviser based in Pittsburgh, Pennsylvania. CIM was founded in 1994 and is organized as a Subchapter S- corporation under the laws of the Commonwealth of Pennsylvania. We have been providing investment advisory services since our founding in 1994. Mr. Andrew C. Fisher is our principal owner. As used in this brochure, the words “CIM”, “we”, and “us” refer to Commonwealth Investment Management and the words “you”, “your” and “client” refer to you as either a client or prospective client of our firm. We offer balanced, equity and fixed-income investment management services to a broad range of clientele based on our diversified, risk-managed investment approach. We provide discretionary and non-discretionary investment management services in accordance with your specific investment policies and guidelines. Discretionary authority includes deciding which securities to buy and sell, when to buy and sell these securities, and in what amounts, tailored to your policies, without obtaining your prior consent or approval for each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm. You may limit our discretionary authority by providing our firm with your restrictions in writing. Description of Investment Advisory Services Equity Management CIM seeks to add value to equity portfolios over and above a defined benchmark by constructing risk managed portfolios that maintain relatively low performance variability versus the benchmark, and which include companies with good growth prospects that are reasonably valued. Key aspects of this process include but are not limited to:  Stay fully invested to the extent practicable, with a target of less than 5% cash.  Broadly diversify each portfolio across sectors and industries.  Add value by selecting companies which provide growth at a reasonable value. Fixed-Income Management CIM’s fixed-income investment management process seeks to add value to a portfolio versus a defined benchmark by balancing credit and interest-rate risk versus total return potential using both a top-down macro-economic analysis and a bottom-up credit assessment. Key aspects of this process include but are not limited to:  Stay fully invested to the extent practicable, with a target of less than 5% cash.  Broadly diversify each portfolio across sectors, industries, and types of securities.  Add value through a combination of sector rotation, interest rate anticipation and individual security selection. Balanced Account Management Our balanced account product combines stocks and bonds in a portfolio based on the client’s asset allocation policy (the minimum and maximum percentage of the total portfolio allowed in separate asset classes like stocks and bonds). The asset allocation is actively managed and is determined based on an assessment of relative value between equities and fixed income and on a macro-economic analysis of the global economy. The equity portion of balanced accounts will include large-cap stocks (managed as discussed under equity management above), and may include mid-cap, small-cap, and international equity exposure. Exposure to mid-cap, small-cap and international stocks could be achieved using exchange traded funds (ETFs). If the balanced portfolio is large enough, this portion of the equity allocation could be invested in a separate managed portfolio, CIM’s core small cap equity product. The fixed income portion of the account will be invested in individual bonds and will be managed as described under Fixed-Income Management above. Types of Investments Client accounts are normally managed using individual common stocks and bonds, exchange traded funds (ETFs) and closed and open-ended mutual funds. Other types of securities may be utilized based on client requirements or requests. You may request that we refrain from investing in particular securities or types of securities by providing us with such instructions in writing. Retirement Investors As a registered investment advisor subject to Section 206 of the Advisers Act, CIM acts as a fiduciary related to the conduct of its investment advisory services. As such CIM has an obligation to act in the best interest of its clients guided by the core fiduciary duties of loyalty and care. In conducting our investment advisory services, CIM will adhere and comply with the following Impartial Conduct Standards; 1. When providing investment advice to a retirement investor, CIM will provide investment advice that is, at the time of the recommendation, in the best interest of the retirement investor. Such advice shall reflect the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims,

based on the investment objectives, risk tolerance, financial circumstances, and needs of the retirement investor, without regard to the financial or other interests of CIM; 2. The recommended transaction will not cause CIM to receive, directly or indirectly, compensation for their services that is in excess of reasonable compensation within the meaning of ERISA section 408(b)(2) and Internal Revenue Code section 4975(d)(2). 3. Statements by CIM to the Retirement Investor about the recommended transaction, fees and compensation, material conflicts of interest, and any other matters relevant to a retirement investor's investment decisions, will not be materially misleading at the time they are made. Rollover to IRA Investors considering rolling over assets from a qualified employer-sponsored retirement plan (“Employer Plan”) to an Individual Retirement Account (“IRA”) should review and consider the advantages and disadvantages of an IRA rollover from their Employer Plan. A plan participant leaving an employer typically has four options (and may engage in a combination of these options): 1. Leave the money in the former employer’s plan, if permitted; 2. Rollover the assets to a new employer’s plan (if available and rollovers are permitted); 3. Rollover Employer Plan assets to an IRA (in such circumstance, a “Rollover IRA”); or, 4. Cash out the Employer Plan assets and pay the required taxes on the distribution. At a minimum, investors should consider fees and expenses, investment options, services, penalty-free withdrawals, protection from creditors and legal judgments, required minimum distributions, and employer stock. CIM encourages you to discuss your options and review the above listed considerations with an accountant, third-party administrator, investment advisor to your Employer Plan (if available), or legal counsel, to the extent you consider necessary. Investors may face increased fees when they move retirement assets from an Employer Plan to a Rollover IRA account. Even if there are no costs associated with the IRA rollover itself, there will be costs associated with account administration, investment management, or both. In addition to the fees charged by CIM, the underlying investment (mutual fund, ETF, or investment manager) may also charge a management fee. Custodial and trading fees may also apply. Additional resources relevant to IRA rollovers are available to investors through FINRA’s web site at www.finra.org. Assets Under Management As of December 31, 2023: Discretionary assets managed $1,094,054,439 Non-Discretionary $ 23,393,486 Total $1,117,447,925 Description of Municipal Advisory Services CIM provides municipal advisory services that include, but are not limited to, developing the structure of the financing, assisting the client in selection of the financing team, coordinating and assisting in the preparation of the client’s official statements, and/or other pertinent documents, and assisting the client in negotiations with the underwriters, banks or other financing sources as applicable. CIM provides municipal advisory services to municipal clients issuing debt. Those services generally include one or more of the following services described below: 1. Develop the structure of the financing, report to the client the results of available financing options and assist the client in the selection of the financing option that is most beneficial to the client. 2. Assist the client in the selection of the financing team members and conduct meetings of the financing team during the creation and execution of a plan of finance; attend meetings as requested by the client or deemed appropriate. 3. As financial advisor, and not as legal counsel expert in legal matters, review the legal aspects of the financing and assist legal counsel in the preparation of any necessary financial documents, as requested. 4. Coordinate and assist in the preparation of the client’s documentation for presentation to the bond insurer (if any) and the credit rating agencies (or lenders, as appropriate). Participate in and initiate credit discussions on behalf of the client. Use our best efforts to ensure that the presentations and discussions will result in the best possible credit rating and most favorable bond insurance commitment (if any), as appropriate. 5. Prepare or assist in the preparation of the client’s official statement(s) (if any) for use in the bond offering(s) (if any). Coordinate the formatting, posting, printing and delivery of the official statement(s) (if any) to the applicable underwriters (if any). 6. Assist the client in its selection of, and negotiations with, (a) underwriters (if any) so as to provide for successful pricing of the client’s bonds (if any) or (b) lenders, as the case may be, in each case so as to obtain optimal structure, redemption features and interest rates for the client’s proposed financing. 7. Perform other services and prepare other documentation that may be advisable.