Registration Status – Registered with the SEC on October 1, 19981 Registered with the State of CA on January 31, 1994 Principal Owners – Jeffrey V. St.Claire James B. Blume Peter B. Reidenbach ADVISORY SERVICES Blume Capital Management, Inc. (“Blume Capital” or the “Firm”), a California corporation, provides investment management and other financial consulting services to individuals and their trusts and estates, pension and profit-sharing plans, charitable foundations and private investment funds. INVESTMENT MANAGEMENT SERVICES Investment management services are provided on a discretionary basis and for individually managed accounts, include, among other services, financial goal setting, risk assessment, strategic asset allocation and the selection and management of securities and investments. Blume Capital accepts clients for which its services are suitable and appropriate. This determination is made through client consultations during which the client and Blume Capital evaluate the client’s investment objectives, financial circumstances, investment experience, time horizon and risk tolerance level. In performing its services, Blume Capital is not required to independently verify any information received from the client or from the client’s other professional advisors and is expressly authorized to rely thereon. Moreover, each client is advised that it remains the client’s responsibility to promptly notify the Firm of any change in their financial situation or investment objectives that would necessitate a review, evaluation or revision by Blume Capital of previous recommendations and/or services. Blume Capital evaluates each new client’s existing investments and where necessary develops a plan to transition such existing investments into or out of the client’s portfolio as required by Blume Capital’s investment strategy. In certain circumstances, typically for clients with $20 million or more in investible assets, Blume Capital may provide investment consulting regarding the use, selection and monitoring of third-party sub-advisors, as well as the determination of appropriate asset allocation. 1“Registration” means only that the Firm meets the minimum requirements for registration as an investment advisor and does not imply that the SEC guarantees the quality of our services or recommends them. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) Blume Capital can be engaged to provide financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) on a stand-alone separate fee basis. Before engaging Blume Capital to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with Blume Capital setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client before Blume Capital commences services. MISCELLANEOUS Client Obligations. In performing its services, Blume Capital shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify Blume Capital if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Blume Capital's previous recommendations and/or services. Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Blume Capital generally recommends that Schwab serve as the broker-dealer/custodian for client investment management assets. Broker- dealers such as Schwab charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including Schwab, do not currently charge fees on individual equity transactions, others do). When beneficial to the client, individual fixed-income and/or equity transactions may be effected through broker-dealers with whom Blume Capital and/or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other SEC registered and FINRA member broker-dealers (in which event, the client generally will incur both the transaction fee charged by the executing broker-dealer and a “trade-away” fee charged by Schwab). These fees/charges are in addition to Blume Capital’s investment advisory fee at Item 5 below. Blume Capital does not receive any portion of these fees/charges. ANY QUESTIONS: Blume Capital’s Chief Compliance Officer, Jeffrey V. St.Claire, remains available to address any questions that a client or prospective client may have regarding the above. Retirement Plan Rollovers. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Blume Capital recommends that a client roll over their retirement plan assets into an account to be managed by Blume Capital, such a recommendation creates a conflict of interest if Blume Capital will earn a new (or increase its current) investment management fee as a result of the rollover. Whether Blume Capital provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Blume Capital is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets to an account managed by Blume Capital. Blume Capital’s Chief Compliance Officer, Jeffrey V. St.Claire, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Please Note: Cash Positions. Blume Capital continues to treat cash as an asset class. As such, unless determined to the contrary by Blume Capital, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Blume Capital’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Blume Capital may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Blume Capital’s advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: Blume Capital’s Chief Compliance Officer, Jeffrey V. St.Claire, remains available to address any questions that a client or prospective may have regarding the above fee billing practice Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion, Blume Capital shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless Blume Capital reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. Please Note: The above does not apply to the cash component maintained within a Blume Capital actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager, and cash balances maintained for fee billing purposes. Please Also Note: The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any Blume Capital unmanaged accounts. ANY QUESTIONS: The Firm’s Chief Compliance Officer, Jeffrey V. St.Claire, remains available to address any questions that a client or prospective client may have regarding the above. Portfolio Activity. As part of its investment advisory services, Blume Capital will review client portfolios on a periodic basis to determine if any changes are necessary based upon various factors,

including but not limited to investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when Blume Capital determines that changes to a client’s portfolio are unnecessary. Clients remain responsible for paying advisory fees during periods of portfolio inactivity. Use of Mutual Funds and Exchange Traded Funds. Blume Capital utilizes mutual funds and exchange traded funds for its client portfolios. In addition to Blume Capital’s investment advisory fee described below, and transaction and/or custodial fees discussed above, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). The mutual funds and exchange traded funds utilized by Blume Capital are generally available directly to the public. Thus, a client can generally obtain the funds recommended and/or utilized by Blume Capital independent of engaging Blume Capital as an investment advisor. However, if a prospective client does so, then they will not receive Blume Capital's initial and ongoing investment advisory services. Please Note-Use of DFA Mutual Funds: Blume Capital utilizes the mutual funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through registered investment advisers approved by DFA. Thus, if the client was to terminate Blume Capital’s services, and transition to another adviser who has not been approved by DFA to utilize DFA funds, restrictions regarding additional purchases of, or reallocation among other DFA funds, will generally apply. Borrowing Against Assets/Risks. A client who has a need to borrow money could determine to do so by using:
• Margin-The account custodian or broker-dealer lends money to the client. The custodian charges the client interest for the right to borrow money, and uses the assets in the client’s brokerage account as collateral; and,
• Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges its investment assets held at the account custodian as collateral; These above-described collateralized loans are generally utilized because they typically provide more favorable interest rates than standard commercial loans. These types of collateralized loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are not without potential material risk to the client’s investment assets. The lender (i.e. custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, Blume Capital does not recommend such borrowing unless it is for specific short-term purposes (i.e. a bridge loan to purchase a new residence). Blume Capital does not recommend such borrowing for investment purposes (i.e. to invest borrowed funds in the market). Regardless, if the client was to determine to utilize margin or a pledged assets loan, the following economic benefits would inure to Blume Capital:
• by taking the loan rather than liquidating assets in the client’s account, Blume Capital continues to earn a fee on such Account assets; and,
• if the client invests any portion of the loan proceeds in an account to be managed by Blume Capital, Blume Capital will receive an advisory fee on the invested amount; and,
• if Blume Capital’s advisory fee is based upon the higher margined account value, Blume Capital will earn a correspondingly higher advisory fee. This could provide Blume Capital with a disincentive to encourage the client to discontinue the use of margin. Please Note: The Client must accept the above risks and potential corresponding consequences associated with the use of margin or a pledged assets loans. Limitations of Planning and Non-Investment Consulting/Implementation Services. If specifically requested by a client, Blume Capital may provide financial planning and consulting services regarding investment and non-investment related matters, such as estate planning, tax planning, insurance, etc. Neither Blume Capital nor its investment adviser representative assists clients with the implementation of any financial plan unless they have agreed to do so in writing. To the extent requested by a client, Blume Capital may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance agents, etc.). Clients are under no obligation to engage the services of any recommended professional. The client retains absolute discretion over all implementation decisions and is free to accept or reject any recommendation made by Blume Capital or its representatives. The engaged unaffiliated licensed professional (e.g., attorney, accountant, or insurance agent), and not Blume Capital, will be responsible for the services provided. If the client engages any recommended professional, and a dispute arises, the client agrees to seek recourse exclusively from the engaged professional. In addition, Blume Capital does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with Blume Capital, if desired. Structured Notes. Blume Capital may purchase Structured Notes for client accounts. A Structured Note is a financial instrument that combines two elements, a debt security and exposure to an underlying asset or assets. It is essentially a note, carrying counter party risk of the issuer. However, the return on the note is linked to the return of an underlying asset or assets (such as the S&P 500 Index or commodities). It is this latter feature that makes structured products unique, as the payout can be used to provide some degree of principal protection, leveraged returns (but usually with some cap on the maximum return), and be tailored to a specific market or economic view. Structured Notes will generally be subject to liquidity constraints, such that the sale thereof before maturity will be limited, and any sale before the maturity date could result in a substantial loss. There can be no assurance that the Structured Notes investment will be profitable, equal any historical performance level(s), or prove successful. Please Note: If the issuer of the Structured Note defaults, the entire value of the investment could be lost. See additional Risk Disclosure at Item 8 below. In the event that a client has any questions regarding the purchase of Structured Notes for their account, or would like to place restrictions on the purchase of Structured Notes for their accounts, Blume Capital’s Chief Compliance Officer, Jeffrey V. St.Claire, remains available to address them. See Risks Associated with Structured Notes at Item 8 below. Client Obligations. In performing our services, Blume Capital shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify Blume Capital if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Blume Capital) will be profitable or equal any specific performance level(s). Cybersecurity Risk. The information technology systems and networks that Blume Capital and its third- party service providers use to provide services to Blume Capital’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Blume Capital’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Blume Capital are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although Blume Capital has established processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that Blume Capital does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Disclosure Brochure. A copy of Blume Capital’s written Privacy Notice, Disclosure Brochure as set forth on Part 2 of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement or Financial Planning Agreement. WRAP FEE PROGRAM Blume Capital does not sponsor or manage client investment assets through a wrap fee program (in which the sponsor arranges for the investor participant to receive investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee). REGULATORY ASSETS UNDER MANAGEMENT As of December 31, 2023, Blume Capital managed $639,914,572 of client assets on a discretionary basis.