DescriptionofAdvisoryFirm The Capital Chart Room LTD® is a registered investment adviser with the U.S. Securities and Exchange Commission (SEC.). The firm was organized as a limited liability company under the laws of the State of Texas in November of 1998 and converted to a limited partnership under the laws of the State of Texas in December of 2001. Jeffrey M. Holler, CFP® founded The Capital Chart Room and continues to own the controlling interest in the firm. AdvisoryServicesOffered TCCR provides financial planning, consulting, and investment management services to individuals, investment limited partnerships, trusts, estates, charitable organizations, corporations and business entities, PlanningAdvisoryandConsultingServices TCCR provides clients with a broad range of comprehensive, integrated financial planning and consulting services in association with its trademarked planning process, TheResults AcceleratorSystem™. A financial plan will address any or all of the following areas:  Living Planning  Business Continuity and Estate Planning  Tax Planning  Charitable Planning  Asset Protection Planning  Personal Investments Integration  Risk Management Planning  Retirement Plan Analysis including: o Review of the Client's Section 401(k) Plan o Review of the Client's IRA or other retirement plans TCCR provides the above services pursuant to one or more written agreements which set forth the terms and conditions under which TCCR shall render its services. In all matters, TCCR's planning services are analytical and advisory only, and do not include any legal, accounting or other professional services. TCCR will work with your legal, accounting and other professional advisors to ensure the coordination of all pieces involved in the financial planning and/or estate planning process. TCCR may recommend the services of itself, and/or other professionals to implement its recommendations. A conflict of interest exists if TCCR recommends its own services. Clients are under no obligation to act upon any of the recommendations made by TCCR under a financial planning or consulting engagement and/or to engage the services of any such recommended professional, including TCCR itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of TCCR’s recommendations. Moreover, clients are advised that it remains their responsibility to promptly notify TCCR if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising TCCR’s previous recommendations and/or services. Clients have five (5) business days from the date of execution of their financial planning agreement with TCCR to terminate services provided by TCCR. Terms and conditions are contained in said agreement. Upon termination, TCCR shall reimburse from the date of termination any fee prepaid to TCCR for financial planning as negotiated with the client; at a minimum, TCCR will reimburse the unused duration of the agreement. InvestmentAdvisoryServices TCCR provides investment advisory services pursuant to a written investment management agreement, which sets forth the terms and conditions under which TCCR shall render its services. Independent Investment Manager Programs TCCR may recommend that certain clients authorize the active discretionary management of a portion of their assets by one or more independent investment managers (“independent managers”), based upon the stated investment objectives of the client. The terms and conditions under which the client shall engage anindependent manager shall be set forth in the Agreement or in separate written agreements between (1) the client and TCCR and (2) the client and the designated independent manager. TCCR shall continue to render advisory services to the client relative to the ongoing monitoring and review of account performance, for which TCCR shall receive a quarterly advisory fee. Factors that TCCR shall consider in recommending independent managers include the client’s stated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. TCCR also reserves the authority to terminate independent managers. TCCR shall generally recommend that clients utilize the brokerage and clearing services of Fidelity Investments and its affiliates (Fidelity), Brown Brothers Harriman & Co. (BBH) or Charles Schwab. TCCR may only implement its investment management recommendations after the client has arranged for and furnished TCCR with all information and authorization regarding accounts with appropriate financial institutions. In addition to TCCR’s written disclosure statement, the client shall also receive a written disclosure statement of the designated independent manager. Certain independent managers may impose more restrictive account requirements and varying billing practices than TCCR. In such instances, TCCR may alter its corresponding account requirements and/or billing practices to accommodate those of the independent manager. Clients have five (5) business days from the date of execution of their investment management agreement with TCCR to terminate services provided by TCCR. Terms and conditions are contained in said agreement. Upon termination after the date of execution, TCCR shall reimburse from the date of termination any fee prepaid to TCCR for investment management as negotiated with the client; at a minimum, TCCR will reimburse the unused duration of the agreement. The Chartered Portfolio Program TCCR also offers The Chartered Portfolio program, which is a fee-based asset management program that allows TCCR the discretion to manage the client's account within

predetermined constraints. Portfolios are designed and maintained to offer flexibility to meet the client's unique investment objectives, financial goals and investment risk tolerance. Each portfolio is designed utilizing strategic asset allocation and diversification techniques. The securities used to implement the strategy will generally consist of exchange traded funds and mutual funds. Stocks, bonds, other general securities, and/or alternative investments may also be considered based on the clients’ stated objectives. TCCR will provide its clients with annual performance reports, monitor their accounts, discuss account performance, and be available to answer questions on a continuing and ongoing basis. The Chartered Portfolio will be adjusted periodically to keep asset allocation and investments in line with the client’s stated objectives. The client’s overall financial condition will be evaluated at least annually to identify any changes in their situation and to determine whether any new circumstances warrant a change in investment objectives and portfolio. TCCR shall generally recommend that Chartered Portfolio clients utilize the brokerage and clearing services of Fidelity Investments and its affiliates (collectively referred to as “Fidelity”) for investment management accounts. TCCR may only implement its investment management recommendations after the client has arranged for and furnished TCCR with all information and authorization regarding accounts with appropriate financial institutions. Clients may incur certain charges imposed by the Financial Institution(s) and other third parties such as fees charged by Independent Managers, custodial fees, charges imposed directly by a mutual fund or exchange-traded fund in the account, which shall be disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Additionally, for assets outside of any wrap fee programs, clients may incur brokerage commissions and transaction fees. Such charges, fees and commissions are exclusive of and in addition to TCCR’s fee. TCCR also may render non-discretionary investment management services to clients relative to: (1) variable life/annuity products that they may own, and/or (2) their individual employer-sponsored retirement plans. In so doing, TCCR either directs or recommends the allocation of client assets among the various mutual fund subdivisions that comprise the variable life/annuity product or the retirement plan. The client's assets shall be maintained either at the specific insurance company that issued the variable life/annuity product owned by the client, or at the custodian designated by the sponsor of the client’s retirement plan. Clients have five (5) business days from the date of execution of their investment management agreement with TCCR to terminate services provided by TCCR. Terms and conditions are contained in said agreement. Upon termination, TCCR shall reimburse from the date of termination any fee prepaid to TCCR for investment management as negotiated with the client; at a minimum, TCCR will reimburse the unused duration of the agreement. Long Road Risk Management Services TCCR has an arrangement with Long Road Risk Management Services, LLC (LRRM) to provide insurance solutions to clients. Clients who choose to purchase insurance coverage through LRRM will need to enter into a customer agreement with LRRM or its affiliate. When a client chooses to purchase an insurance product through LRRM on certain insurance solutions, TCCR receives a benefit in the form of an annual fee to provide investment advisory services in the nature of advice concerning the management of the insurance products and to deliver the annual policy report to clients who own them. Valmark Policy Management Company, LLC and Long Road Risk Management Services, LLC are both subsidiaries of Valmark Securities, Inc. Neither VPMC nor LRRM are affiliated with TCCR. Assets Under Management As of December 31, 2023, The Capital Chart Room LTD® managed approximately $326,462,923 on a discretionary basis and $12,247,095 on a non-discretionary basis. OtherInformation Additions may be in cash or securities, provided that TCCR reserves the right to liquidate any transferred securities, or decline to accept particular securities into a client’s account. TCCR may consult with its clients about the options and ramifications of transferring securities. However, clients are advised that when transferred securities are liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charges) and/or tax ramifications. TCCR’s clients are advised to promptly notify TCCR if there are any changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon TCCR’s management services. Neither TCCR nor the client may assign the Agreement without the consent of the other party. Transactions that do not result in a change of actual control or management of TCCR shall not be considered an assignment. A copy of TCCR’s privacy policy notice and a written disclosure statement that meets the requirements of Rule 204-3 of the Investment Advisers Act of 1940, as amended (“Advisers Act”), shall be provided to each client prior to or contemporaneously with the execution of the Agreement. Any client who has not received a copy of TCCR’s written disclosure statement at least forty-eight (48) hours prior to executing the Agreement shall have five (5) business days subsequent to executing the agreement to terminate TCCR’s services without penalty.