Firm Description Camden Financial Management, Inc. (“Camden”) was founded in 1996. Camden provides customized Investment Advisory and Financial Planning Services. These services are provided to individuals, families, retirement plans, trusts and estates. Investment advice is personalized through conversations with Clients and may include the evaluation of the Client’s: financial objectives, risk parameters, financial structure, cash management and life experiences. Camden strongly believes that building customized portfolios is not an exact science since a Client’s tolerance for stock market risk is not always a static measurement. It has been Camden’s experience that Clients are willing to take on greater risk/uncertainty during up markets and exhibit less of a willingness to take on risk/uncertainty during down markets. Thus, Camden knows it may take a few market cycles to “fine tune” and arrive at a portfolio structure that ultimately meets the Client’s desires. Within our Investment Advisory Service, Camden spends about 50% of our time helping clients with non-investment oriented issues. Camden refers to these non- investment services as Financial Planning Services. Financial Planning Services are very broad in nature and are Client specific, but may include tax planning, risk management/insurance planning, education funding, retirement planning, and estate planning. Camden is strictly a fee-only investment management and financial planning firm. The firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. The firm is not affiliated with entities that sell financial products or securities. No commissions or finder’s fees are accepted in any format. Camden does not act as a custodian of Client assets. Assets always remain in the name of the Client and Camden does not accept title or vesting of any assets within the firm’s name. All assets are held at large, “well known” custodians. Camden implements the recommended investment strategy via a limited power of attorney provided to the firm by the Client. The nature of this limited power of attorney is discussed in greater detail in the following pages. After Camden has spent time understanding the Client’s financial situation and desires, a “Recommendation Letter” is drafted to propose the specific investment allocation to be utilized. The Client has the full authority to accept or reject the recommendations in this Recommendation Letter. Once the investment allocation is approved by the Client, Camden will proceed in implementing the allocation over the time period noted in the Recommendation Letter. Periodic updates are provided to Clients as to the recommended current course of action. Camden believes that two-way communication is imperative to achieve a successful outcome. Camden utilizes articles, emails, phone conversations and face to face meetings as modes of communication. Camden fully relies on Clients to update them immediately of any changes in their financial or personal lives. It is also crucial that the Client maintain contact with Camden via one of the above modes of communication. The Recommendation Letter is utilized for the noted implementation period. Beyond the implementation of the Recommendation Letter, Camden will make rebalancing and investment changes without notice to the Client. It is our intention, whenever possible, to communicate our future plans in our articles, but we know that a portion of investments will need to be effectuated in a timelier manner, without Client notice. Some months, or possibly a few years, after the Recommendation Letter has been fully implemented, the Advisor will write an Investment Policy Statement (IPS) for Client. It is imperative that the Client has other professional relationships (e.g., lawyer, accountant, insurance agents, etc.) that are engaged directly by the Client on an as- needed basis. It is the Client’s responsibility to make sure these other professionals are being proactive and contacting the Client if any changes need to be made within their area of specialty. All of these professionals provide unique and distinct services beyond the services that are provided by Camden, thus the importance of these other relationships. Camden will occasionally write articles on legal, tax and insurance topics, but it is the Client’s responsibility to take the next step in contacting their particular professional to implement any desired changes within these specific areas. We are pleased to discuss options before the Client contacts their other professionals, but the Client needs to take the initiative and assume responsibility in making contact. One of the main reasons that Camden prepares an annual Net Worth Statement for Clients is for this document to be utilized to better inform these “other professionals” as to the Client’s current financial position. It is the policy of Camden to eliminate conflicts of interest wherever possible. It may not be possible to eliminate conflicts of interest in every situation. Camden will disclose any known conflicts of interest in writing. The initial meeting(s), which may be by telephone and/or in person, is/are free of charge and is/are considered an exploratory interview to determine the needed scope of services and to determine if there will likely be a mutual benefit to both the Client and Camden. Principal Owners Randy Oldenburg is the 100% stockholder. Types of Advisory Services The only advisory service Camden provides is the above-mentioned Investment Advisory Service. On a regular basis, Camden furnishes advice to Clients on matters not involving securities. We refer to these other services as Financial Planning Services. These other services are very broad in scope and are typically driven by specific Client requests or needs, but they may include retirement planning, tax planning, risk management/insurance planning and estate planning. It is Camden’s belief that one of the differentiating elements of our firm is the time we spend with Clients on these non-investment advisory issues. As of December 31, 2023, Camden manages approximately $134,967,514 in assets for approximately 43 clients. Approximately $134,967,514 is managed on a discretionary basis, and $0 is managed on a non-discretionary basis. Tailored Relationships Through our initial conversations with Clients, Camden tailors a customized investment allocation that is communicated to the Client in what we refer to as the “Recommendation Letter.” The presentation

and conversation about this letter give the Client the forum to accept or decline the initial recommendations. Camden provides periodic updates to Clients on our beliefs in the macro economy. These updates allow for the Client to contact Camden and discuss any possible disagreements regarding our investment recommendations or broad global beliefs. Camden will fully rely on the Client to contact us with any significant “big picture” disagreements with our recommended investment theories. Agreements may not be assigned without Client consent. Types of Agreements Investment Advisory Agreement The vast majority of Clients elect to hire Camden under an Investment Advisory Agreement to provide Asset Management. Due to Camden’s high minimums, the firm naturally gravitates to Clients that are well on their way to being financially independent or have reached the point of not needing to continue to work. Most Clients hire Camden for the management of their assets, but over numerous years Clients come to understand the significant value in ongoing, broad non-investment oriented services that are provided by Camden. Camden believes that the pursuit of these Financial Planning topics is crucial to obtaining financial success. Financial Planning has become synonymous with a formalized, 60-page document. We believe Financial Planning is the ongoing pursuit of issues that will more fully maximize clients’ Net Worth and improve one’s quality of life. The Investment Advisory Service provides the ongoing management of the Client’s investment portfolio and the continuous pursuit of financial planning issues that need to be integrated into the Client’s financial structure. If the Client wants an upfront comprehensive analysis of all financial planning issues, the Client must initially hire Camden under a Financial Planning Document Preparation Agreement. The Financial Planning Services under the Investment Advisory Agreement should in no way be construed as a comprehensive Financial Plan. We understand how Clients initially minimize these non-investment services addressed under our Investment Advisory Agreement, thus the following list of recently written articles may help prospective Clients understand the depth of our additional services: Estate Planning Medicare and Supplemental Policies Asset Protection College Planning – 529 Plans Charitable Gifting Missing Money (State Dept. Rev.) Property Casualty/Umbrella Policies Life Planning Beneficiary Designations Credit Reports – FICO Scores Roth Conversions Client’s Health Long-Term Care Insurance Tax Update Identity Theft Reverse Mortgages As directly pertaining to Asset Management, the following services will be provided:
• Risk Tolerance Determination
• Portfolio design to pursue financial independence
• Tailored Asset Allocation Plan with Specific Investment Recommendations
• Implementation and Ongoing support o Account establishment and/or account transfer assistance o Quarterly appraisal and performance reports o Ongoing portfolio monitoring and management – we spend a significant amount of time researching how to best position your portfolio relative to the current economic environment o Quarterly updates as to potential investment changes due to changes in the macro worldwide economy o Constant access to the Advisor via phone, email or in person to evaluate life changes and family financial issues The following is a list of services that we provide annually that only partially relate to management of Client’s investments: 1) Tax Reporting including Realized Gain and Loss reports and detailed notes to the Client’s accountant to assist in completion of the Client’s tax return. Upon Client direction, Camden communicates directly with the Client’s accountant as to any tax reporting revisions by the custodian. 2) Required Minimum Distribution calculation and distribution plan (if applicable). 3) Annual Net Worth Calculation to determine progress of the Client’s overall financial situation. Camden prepares Net Worth Statements during the second quarter of the year. Camden sends the Clients out a query for asset values at the beginning of the second quarter. The Client is encouraged to provide the Net Worth Statement to their estate planning attorney and insurance agent to ensure that these other professionals understand the Client’s current structure and current asset values to determine if changes need to be made to estate planning documents or insurance coverage. 4) Tax Loss Harvesting opportunities are pursued throughout the year. At times, there can be significant value to the Client in this service. 5) Year-end tax evaluation to determine if tax deferral or tax acceleration is beneficial for the Client. In an example of this analysis, Camden might determine if a Roth Conversion or additional income will benefit the Client in normalizing tax liabilities over numerous years. The scope of work and fee for an Investment Advisory Service relationship is provided to the Client in writing prior to the start of the relationship via a formalized contract. The annual Investment Advisory Service Agreement fee is based on a percentage of the investable assets according to the following schedule: Portfolio Value Quarterly Rate Equivalent Annual Rate < or = $2,000,000 0.1875% 0.75%, plus >$2,000,000 0.125% 0.50% Current Clients under previous contracts may have a lower fee than the fee schedule above. Camden has a minimum annual fee of $20,000. Camden, in its sole discretion, may reduce the minimum fee and/or charge a lesser investment advisory fee based upon certain extenuating factors. Although the Investment Advisory Service Agreement is an ongoing agreement, the length of service to the Client is at the Client’s discretion. The Client or the Advisor may terminate an Agreement by written notice to the other party. At termination, fees will be billed on a pro rata basis for the portion of the quarter completed. The portfolio value at the completion of the prior full billing quarter is used as the basis for the fee computation. Termination of Agreement A Client may terminate any of the aforementioned agreements at any time by notifying Camden in writing and paying the pro-rata portion of the investment advisory expense for the given quarter. Camden may terminate any of the aforementioned agreements at any time by notifying the Client in writing. If the Client made an advance payment, Camden will refund any unearned portion of the advance payment.