Blue Ocean Capital (hereinafter “BOC”) has been in business since October 13, 1997. The principal owners are Mark Bradley Elhilow, CPA/PFS and Ronald Gregory Smith, CPA. As of December 31, 2022, Blue Ocean Capital’s discretionary assets under management totaled $456,800,000. Blue Ocean Capital offers the following services to advisory clients: Investment Supervisory Services Investment Supervisory Services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring BOC manages client portfolios based on the individual goals, objectives, time horizon, and risk tolerance of each client. BOC creates an Investment Policy Statement for each client, which outlines the client’s current situation (financial position, liquidity needs, time horizon, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. BOC evaluates the current investments of each client with respect to their liquidity needs, risk tolerance levels and time horizon. BOC primarily manages client accounts on a discretionary basis and will select investments and execute transactions without permission from the client in advance. However, BOC may also work with clients on a non-discretionary basis based on the scope of the client engagement and needs of the specific client. Risk tolerance levels are documented in the Investment Policy Statement, which is agreed upon with each client. BOC offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (financial position, liquidity needs, time horizon, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. BOC invests client portfolios in mutual funds, equities, bonds, fixed income, debt securities, ETFs, hedge funds, third party money managers, MLPs, REITs, private placements, and government securities. BOC may use other securities as well to help diversify a portfolio when applicable. Clients may impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent BOC from properly servicing the client account, or if the restrictions would require BOC to deviate from its standard suite of services, BOC reserves the right to end the relationship. Selection of Other Advisers BOC

may direct clients to third party money managers. Before selecting other advisors for clients, BOC will always ensure those other advisers are properly licensed or registered as investment advisers. For clients whose financial situation warrants it, BOC may recommend unaffiliated private funds as an investment option for the client’s portfolio. There are unique risks associated with investments in private funds, including the risk of loss of the client’s entire investment. Clients will be presented with the fund’s offering document, which includes a complete list of the risks inherent in the investment. Clients will be required to sign a subscription agreement accepting the terms and conditions of their investment in the private fund. Family Office Services BOC provides family office services to individuals, their families and related closely held businesses. These services vary in nature based on the scope and complexity of each family’s circumstances and are customized to meet the needs of each specific client. Family office services position the firm as the capstone adviser, often serving in the capacity as the family’s CFO. Some of the core services provided include, but are not limited to, sourcing client mail, records repository, cash management, banking, bill payment, cash disbursements, financing, management of insurance needs, family wealth counseling, capital allocation, estate planning, business acquisition due diligence, administrative support services, account aggregation, comprehensive accounting and reporting. As of December 31, 2022, BOC monitors, reports and advises on $279,900,000 of assets through family office services, of which BOC has discretion on $135,100,000. Financial Planning Financial planning services cannot be purchased separately from investment advisory services. However, basic financial planning services may be provided in connection with the development of each client's investment policy statement. Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Tax and Accounting Services BOC employs a team of CPAs that provide tax and accounting services to individuals, trusts and closely held businesses. Tax and accounting services can be obtained separately from investment advisory, family office and financial planning services; however, BOC provides many synergies when clients engage multiple areas of BOC’s offerings, including tax and accounting services. Tax and accounting services include, but are not limited to, tax compliance and planning services.