REGISTRATION AND PRINCIPALS Hutchinson Capital Management Corporation ("Hutchinson Capital" or "Adviser") is an independently owned and operated SEC Registered Investment Adviser. The Firm is headquartered in San Rafael, California. The Firm has been registered1 with the SEC since 1995. The principal owners of Hutchinson Capital are:
• Steven K. Wilkes, CEO, Chief Compliance Officer, Portfolio Manager
• Gage T. Houser, President, Chief Financial Officer, Portfolio Manager ASSETS UNDER MANAGEMENT AS OF DECEMBER 31, 2023 Discretionary Assets – $827,199,857 Non-discretionary Assets – $5,765,588 ADVISORY SERVICES Hutchinson Capital provides investment management services and personalized advice for individual, family, trust, retirement plan, and charitable organization clients. We offer integrated investment advisory services, combining asset management with financial planning, under a single client advisory engagement. INVESTMENT MANAGEMENT SERVICES Hutchinson Capital’s investment approach focuses on the specific goals, objectives, and needs of clients. Preservation of wealth and growth of capital are objectives common to the vast majority of clients. Clients are typically financially conservative and often are not in a position to re-create their wealth and therefore preservation of capital is of paramount importance. However, the Firm recognizes that each set of circumstances and relationship is unique. While most portfolios are typically invested in the same 20-30 equity positions across client accounts, the asset allocation or mix between stocks, bonds, and cash investments is customized to the specific needs and circumstances of each client. Factors considered in the asset allocation decision include the client’s investment objectives, risk tolerance, investment time horizon, liquidity needs (including gifting, home purchase, retirement etc.), and other available resources (including Social Security, real estate, outside investments etc.). For fee-paying clients, an Investment Policy Guideline (IPG) document is prepared by a Hutchinson Capital portfolio manager and signed by the client. The purpose of the IPG is to ensure the prudent management of a client’s portfolio by clarifying the client’s unique circumstances and objectives. The IPG documents the major goals of the client, the client’s current situation, and time horizon, among other factors. Also, the IPG includes a recommended target asset allocation between stocks, bonds, and cash. The IPG is reviewed with the client periodically and updated if there are material changes in the client’s situation. The Firm typically invests in individual equity, fixed-income and cash equivalent marketable securities for separately managed accounts. Additionally, for certain accounts and at its discretion the Firm also invests in exchange traded funds (ETFs) and mutual funds. The equity investment approach is characterized as a 1 The use of the term “registered investment adviser” and description of Hutchinson Capital Management Corporation and/or its associates as “registered” does not imply a certain level of skill or training. “Registration” means only that the Firm meets the minimum requirements for registration as an investment advisor and does not imply that the SEC or other regulator guarantees the quality of the services or recommends them. value style where the Firm invests for the long-term in high quality companies which are temporarily out of favor, in its view. The Firm believes buying companies with depressed stock prices minimizes downside risk and improves the chances of achieving competitive returns. Most client accounts also include some exposure to investment grade fixed income securities using a laddered approach to spread the maturities with the objectives to reduce volatility, provide diversification, and generate income. The Firm has followed the same investment philosophy since it was founded in 1995. The Firm can accommodate investment restrictions in client portfolios, and these may be documented in the IPG as well. These restrictions are often based upon social, environmental, religious and/or other concerns of clients. DIMENSIONAL

FUND ADVISORS LP SMA AND SPIDERROCK PROGRAMS Hutchinson Capital has entered into a sub-advisory agreement with Dimensional Fund Advisors LP (“DFA”) whereby a client may request enrollment of all or a portion of their Hutchinson advised account into a DFA sub-adviser account program. In such cases, Hutchinson Capital selects an investment strategy on behalf of the client, and the client, through Hutchinson Capital, retains the ability to customize the selected investment strategy by restricting the account from holding securities from an issuer or group of issuers on environmental, social, governmental, religious or other preferences. Clients participating in the DFA sub-advised account program should carefully review the applicable DFA investment management agreement and investment guidelines selected for their account with their Hutchinson Capital advisor. DFA reserves the right to not accept certain restrictions in its discretion. Hutchinson Capital also has entered into a sub-advisory agreement with SpiderRock Holdings, LLC, the developer of a trading platform that provides institutional clients with tools to construct, manage, and scale equity, futures and option investment strategies. Through the SpiderRock platform, Hutchinson Capital can access sub-advisers that focus on options strategies for those of our clients that are interested in moving a portion of their portfolios into options holdings. FINANCIAL PLANNING AND FINANCIAL CONSULTATION SERVICES Upon client request, Hutchinson Capital provides financial planning services which may include a financial review and analysis of some or all of the following areas:
• Determining Financial Objectives
• Asset Allocation Review
• Retirement Plan Analysis
• Employee Stock Option Analysis
• Education Funding Analysis
• Mortgage/Refinance Evaluation
• Estate Plan Review
• Charitable Planning and Gifting
• Cash Flow Management Review
• Other financial or investment analysis
• Review of Insurance Needs GENERAL NOTICE In performing its services, Hutchinson Capital relies upon the information received from its clients or from their other professional legal and accounting advisors and is not required to independently verify such information. Clients must promptly notify Hutchinson Capital of any change in their financial situation or investment objectives that would necessitate a review or revision by the Firm’s portfolio managers of the client’s portfolio and/or financial plan. FIDUCIARY STATUS When Hutchinson Capital provides investment advice to you regarding your investment accounts, including your retirement plan account or individual retirement account, we are fiduciaries within the meaning of certain state and federal laws such as the Employee Retirement Income Security Act and/or the Internal Revenue Code and the regulations of the U.S. Securities and Exchange Commission, as applicable. These regulations require us to act in your best interest and not put our interests ahead of yours. TERMINATION OF AGREEMENT Clients or the Firm may terminate the relationship at any time upon written notice to the other party. The Firm does not assess any fees related to termination but will be entitled to all management fees earned up to the date of termination. Any earned investment management fees owed to the Firm will be billed to the client, or where authorized, deducted from the client’s account, on a pro rata basis determined on the amount of time expired in the billing period. Any unearned prepaid management fees will be refunded to the client. For new clients of the Firm, if a copy of this Form ADV Part 2A disclosure statement was not delivered to the client 48 hours or more before the client enters into a written advisory agreement with the Firm, then the client has the right to terminate the agreement without penalty within five (5) business days after entering into the agreement. An investment advisory agreement is considered entered into when all parties to the agreement have signed the agreement. If the client terminates the agreement on this basis, all fees paid by the client will be refunded. However, any transaction costs imposed by an executing broker or custodian for establishing the custodial account or for trades occurring during those five days are non- refundable.