A. The Registrant is a limited liability company formed on January 14, 1998 in the state of North Carolina. The Registrant became registered as an Investment Adviser Firm in January 2001. The Registrant is owned by April Y. Beason, Erika L. Mielke, Jennifer L. Jamison-Craver, Paige P. Birchfield, Scott D. Jones, Scott E. Cawood and William E. Hollan, III. Mr. Cawood is the Registrant’s Chief Executive Officer and Chief Investment Officer. Mr. Jones is the Registrant’s President. B. As discussed below, the Registrant offers to its clients (individuals, pension and profit sharing plans, business entities, trusts and charitable organizations, etc.) investment advisory services and, to the extent specifically requested by a client, financial planning and related consulting services. Investment Advisory Services The client can determine to engage the Registrant to provide discretionary and/or non- discretionary investment advisory services on a fee-only basis. The Registrant’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under the Registrant’s management (between negotiable and 1.25%) as outlined in Item 5 below. Financial Planning and Consulting Services (Stand-Alone) To the extent specifically requested by a client, the Registrant may determine 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 fee basis. Registrant’s planning and consulting fees are negotiable, but generally range from a flat fee of $3,000 to $7,000, depending upon the level and scope of the service(s) required and the professional(s) rendering the service(s). If the client chooses to renew the financial planning engagement in subsequent years the annual renewal fee will be determined at the time of reengagement. Miscellaneous Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent specifically requested, Registrant will generally provide planning and consulting services regarding non-investment related matters, such as tax and estate planning, insurance, etc. Registrant, in its sole discretion, based upon various factors such as complexity and assets under management, may determine to provide such services inclusive of its advisory fee set forth at Item 5 below (exceptions will occur based upon assets under management, advanced planning needs, special projects, etc. for which Registrant may charge a mutually agreeable additional fee and/or require a stand-alone engagement). Please Note: Registrant does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, Registrant does not prepare legal documents, prepare tax returns, or sell insurance products. To the extent requested by a client, we may recommend the services of other ADV Part 2A Brochure 4 professionals for non-investment implementation purpose (i.e. attorneys, accountants, insurance agents, etc.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Registrant and/or its representatives. Please Also Note: If the client engages any professional (i.e. attorney, accountant, insurance agent, etc.), recommended or otherwise, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from the engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not Registrant, shall be responsible for the quality and competency of the services provided. Right Capital. In conjunction with the services provided by Right Capital, Registrant may also provide financial planning reports or other periodic comprehensive reporting services, which can incorporate all of the client’s investment assets including those investment assets that are not part of the assets managed by Registrant (the “Excluded Assets”). Registrant’s service relative to the Excluded Assets is limited to reporting services only, which does not include investment implementation. Because Registrant does not have trading authority for the Excluded Assets, to the extent applicable to the nature of the Excluded Assets (assets over which the client maintains trading authority vs. trading authority designated to another investment professional), the client (and/or the other investment professional), and not Registrant, shall be exclusively responsible for directly implementing any recommendations relative to the Excluded Assets. The client and/or their other advisors that maintain trading authority, and not Registrant shall be exclusively responsible for the investment performance of the Excluded Assets. Without limiting the above, Registrant shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that Registrant provide investment management services with respect to the Excluded Assets, the client may engage Registrant to do so pursuant to the terms and conditions of the Investment Advisory Agreement between Registrant and the client. In addition, Right Capital also provides access to other types of information, including financial planning concepts, which should not, in any manner whatsoever, be construed as services, advice or recommendations provided by Registrant. Please Note: Retirement Rollovers-Potential for Conflict of Interest: 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 Registrant recommends that a client roll over their retirement plan assets into an account to be managed by Registrant, such a recommendation creates a conflict of interest if Registrant will earn new (or increase its current) compensation as a result of the rollover. When acting in such capacity, Registrant serves as a fiduciary under the Employee Retirement Income Security Act (ERISA), or the ADV Part 2A Brochure 5 Internal Revenue Code, or both. No client is under any obligation to roll over retirement plan assets to an account managed by Registrant. Registrant’s Chief Compliance Officer, April Y. Beason, 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. Custodian Charges-Additional Fees: As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Registrant generally recommends that Fidelity (and Schwab for 401k plans-see below) serve as the broker- dealer/custodian for client investment management assets. Broker-dealers such as Fidelity charge transaction fees for effecting securities transactions. In addition to Registrant’s investment advisory fee referenced in Item 5 below, the client will also incur transaction fees to purchase securities for the client’s account (i.e., mutual funds, exchange traded funds, individual equity and fixed income securities, etc.) Registrant’s Chief Compliance Officer, April Y. Beason, remains available to address any questions that a client or prospective client may have regarding the above. Please Note-Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded funds are available directly to the public. Thus, a prospective client can obtain many of the funds that may be utilized by Registrant independent of engaging Registrant as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Registrant’s initial and ongoing investment advisory services. Please Also Note: In addition to Registrant’s investment advisory fee described below, and transaction and/or custodial fees discussed below, 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). Registrant’s Chief Compliance Officer, April Y. Beason, remains available to address any questions that a client or prospective client may have regarding the above. Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Registrant will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Registrant determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Registrant will be profitable or equal any specific performance level(s). Please Note: Non-Discretionary Service Limitations. Clients that determine to engage the Registrant on a non-discretionary investment advisory basis must be willing to accept that the Registrant cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that Registrant would like to make a transaction for a client’s account, and client is unavailable, the Registrant will be ADV Part 2A Brochure 6 unable to effect the account transaction (as it would for its discretionary clients) without first obtaining the client’s consent. ERISA Plan Engagements Trustee Directed Plans. Registrant may be engaged to provide investment advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, Registrant will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). Registrant will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and the Firm. Participant Directed Retirement Plans. Registrant may also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a Retirement Plan Services Agreement between Registrant and the Plan. For such engagements, Registrant shall assist the Plan sponsor with the selection of an investment platform from which Plan participants shall make their respective investment choices (which may include investment strategies devised and managed by Registrant that are made available to Plan participants on the Envestnet platform), and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision making process. Please Note: Schwab/Envestnet Platform. The Registrant generally provides services for participant directed retirement plans in conjunction with the custody and platform services provided by Schwab and Envestnet, respectively. The terms and conditions of the Plan’s engagement of Schwab and Envestnet, including transaction fees (Schwab) and platform fees (Envestnet) payable, are set forth in separate written agreements between the Plan and Schwab and Envestnet, respectively. Please Further Note: The Plan is under no obligation to utilize Schwab or Envestnet, and can engage the Registrant’s services using the custodian and/or platform provider of its choosing. Trade Error Policy—Registrant shall reimburse accounts for losses resulting from the Registrant’s trade errors, but shall not credit accounts for such errors resulting in market gains. The gains and losses are reconciled within the Registrant’s custodian firm account. On a monthly basis gains and losses are offset within the custodian firm account, Registrant absorbs the cost of losses while gains are allocated to a designated charity. Client Obligations—In performing its services, Registrant 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 his/her/its responsibility to promptly notify the Registrant if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services. ADV Part 2A Brochure 7 C. The Registrant shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, the Registrant shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on the Registrant’s services. D. The Registrant does not participate in a wrap fee program. E. As of December 31, 2023, the Registrant had $942,442,025 in assets under management on a discretionary basis and $14,279,671 in assets under management on a non- discretionary basis.