Item 5 - Additional Compensation……………………………………………………………………………..18 Item 6 - Supervision……………………………………………………………………………………………18 Item 7 – Important Firm Policies …………………………………………………………………….…….19-22 Addressing Conflicts……………………………………………………………………………….……….19 Management of Other Accounts……………………………………………………………………….........19 Disclosure to Plan Sponsors under 408(b)(2) Form 5500…………………………………………………. 20 Anti-Money Laundering………………………………………………………………………..……......23-21 Privacy…………………………………………………………………………………………...………21-22 iii JRL Capital Advisors LLC (JRL) is an SEC registered investment adviser. The firm’s founding Member is Larry R. Law. The firm was organized as an LLC in 1999. The firm is owned 90% directly by JRL Capital Management Group and 10% directly by Larry R. Law. The firm is owned 100% indirectly by Larry R. Law. Larry R. Law has served as the President, Chief Operating Officer and Chief Compliance Officer of JRL Capital Advisors LLC since its inception as an investment advisor firm. Larry R. Law has over thirty-five (35) years of financial industry experience. The amount of the total assets supervised as of the firm’s annual amendment dated December 31, 2023 on a non-discretionary basis was $104,698,537.54. JRL Capital Advisors LLC provides:  portfolio management for individuals and/or small businesses;  portfolio management for business or institutional clients (other than investment companies);  the selection of other advisers; and,  consulting services for investors and retirement plans. JRL manages investment advisory accounts not involving Investment Supervisory Services. JRL will manage advisory accounts on a non-discretionary basis only. Account supervision is guided by the stated objectives of the client. JRL is aware that most, if not all, of its clients employ the services of one or more unaffiliated additional advisors or investment brokers to handle their investment needs, and that JRL is being utilized as only one resource in an overall investment strategy. The scope and nature of JRL’s services will be outlined in more detail in each client’s documentation. Each portfolio is designed to meet a particular investment goal which the client and JRL have determined is suitable to the client's circumstances. If requested, JRL will help create a portfolio which may consist of one or all of the following:  individual equities and investment funds;  bonds and bond funds;  other investment products (including alternative investments); and,  no-load, load-waived, or front-load mutual funds. Once the appropriate allocation to suit the client’s needs has been determined, JRL Advisors will review the portfolio as contracted for by the client or upon client request, and if necessary, may adjust the portfolio based on each client's individual desires. Each client has the opportunity and responsibility to place restrictions on the types of investments to be held in the portfolio. When appropriate to the needs of the client, JRL Advisors may recommend the use of margin transactions. Because this investment strategy involves a certain additional degree of risk, it will only be recommended when consistent with the client's stated tolerance for risk and stated investment goals. In general, advisory matters may include providing investment advice to:  individuals;  pension and profit sharing plans;  trusts;  estates;  charitable organizations; and,  corporations or other business entities. The advisory services provided to clients may include the following types of investments:  equity and debt securities including exchange-listed securities and securities traded over-the-counter;

 investment company securities including variable life annuities, variable annuities and mutual fund shares;  interests in partnerships, real estate investment trusts, oil and gas interests and other alternative investments; and,  other types of public or private investments. Third Party Manager Selection Services JRL Advisors also provides access to investment service programs in which client accounts are managed by independent third party investment advisers with whom Investors contract for their services. These programs provide additional investment opportunities among:  mutual funds;  variable annuities;  stocks;  bonds; and,  additional securities. Based on a client's individual circumstances and needs, JRL will assist the client in determining which independent adviser's portfolio management services are appropriate for that client. Factors considered in making this determination include:  account size;  risk tolerance;  investment experience;  asset availability; and,  investment style. Modifications of a client’s portfolio are done within the client's stated objectives as directed and/or approved by the client and will be implemented by the client’s investment adviser. At the time of conducting the advisory solicitation, JRL Advisors will ensure that all federal and/or state specific requirements governing solicitation activities shall be met. For California Residents: California clients will only be referred to third-party money managers licensed as an investment adviser in the State of California, notice filed with the California Department of Corporations, or otherwise exempt from California filing requirements. Managed Account Program (MAP) Certain advisory clients of JRL may participate in Managed Account Programs (the "Program") sponsored by Investment Management Companies ("IMC"). To participate in the Program, JRL, IMC, and each investor execute agreements (hereinafter, a "Managed Account Agreement") providing for the management of certain investor assets in accordance with the terms thereof. Pursuant to a Managed Account Agreement, the investor appoints JRL, through its affiliates, as its investment adviser to assist the investor in selecting an asset allocation strategy, which could include the percentage of investor assets allocated to designated portfolios of separate securities (each, a "Separate Account Portfolio") and may include a percentage of assets allocated to a portfolio of mutual funds or other investments sponsored by the IMC or an affiliate thereof. The investor appoints the IMC to manage the assets in each Separate Account Portfolio in accordance with a strategy selected by the investor. The IMC may delegate its responsibility for selecting particular securities to one or more portfolio managers. The Program seeks to provide a diversified portfolio in order to meet an investor's goals. The fees payable to the IMC for a MAP program will vary and will be disclosed to each client in the Managed Account Agreement. Consulting Services Clients can also receive conceptual investment advice on a more limited basis. This may include advice only on isolated area(s) of concern such as:  estate planning;  corporate or not for profit planning;  Individual retirement planning and corporate retirement plans;  reviewing a client's existing portfolio; or,  any other specific topic. JRL also provides specific consultation and administrative services and advice on non-securities matters. Generally, this is in connection with the rendering of estate planning, insurance, and/or annuity advice.