Guiry Capital Management, LLC (also referred to as “Advisor” in the text of this Brochure) is a fee- based investment adviser that has been registered with the SEC since 2002. Martin D. Guiry is the owner and managing member of Guiry Capital Management, LLC. Guiry Capital Management’s investment advisory services include: (a) developing asset allocation plans for clients; (b) recommending and selecting investments within each asset class (such as fixed income, equities, commodities); and (c) single stock and portfolio risk management. These investment advisory services are offered to clients on either a nondiscretionary or discretionary basis. As of 3/27/2024, client assets under advisory/management are equal to approximately $225,000,000. Approximately 83% of client assets and 68% of client accounts are advised by Guiry Capital Management on a nondiscretionary basis. Guiry Capital Management continuously monitors client asset allocation plans, and the investments made within each asset class, and discusses with clients whether any adjustments or modifications should be made on an ongoing basis. Asset Allocation: Guiry Capital Management develops and tailors asset allocation plans for clients based on the circumstances and considerations of each client. Client considerations include investment experience and sophistication, risk tolerance, growth and/or income objectives, investment time horizon, any current or future requirements for income and capital withdrawals, and tax circumstances (if applicable). Clients may have more than one than one account being overseen and managed by Guiry Capital Management, and these accounts may have different investment objectives and asset allocation plans. Recommendation and Selection of Investments within each Asset Class: Guiry Capital Management recommends and selects investments in the following broad asset classes: Cash and Fixed Income: Guiry Capital Management may invest in Cash and Fixed Income for its clients by: (a) investing in unaffiliated fixed income mutual funds and/or separate account managers; (b) purchasing specific fixed income securities such as investment grade corporate bonds and municipal bonds; or (c) investing in a combination of unaffiliated mutual funds/separate account managers, and specific fixed income securities. Equities: Guiry Capital Management may invest in Equities for its clients by: (a) investing in unaffiliated mutual funds and/or separate account managers that invest in equities; (b) purchasing specific equities securities such as (but not limited to) dividend-paying stocks and/or exchange traded funds; or (c) investing in a combination of unaffiliated mutual funds/separate account managers,

and specific equities securities. Commodities: Guiry Capital Management may invest in Commodities for its clients by: (a) investing in unaffiliated mutual funds and/or separate account managers that invest in commodities or commodities-linked securities; (b) purchasing specific securities, such as exchange-traded funds that are linked to commodities; or (c) investing in a combination of unaffiliated mutual funds/separate account managers, and specific commodities-linked securities. Additional Asset Classes: Guiry Capital Management may also recommend and select investments in additional asset classes such as publicly-traded REITs (real estate investment trusts), publicly- traded MLPs (Master Limited Partnerships), and foreign currencies. Investments in these additional asset classes may be made by: (a) investing in unaffiliated mutual funds and/or separate account managers; (b) purchasing specific REIT and MLP securities and/or exchange traded funds; (c) purchasing specific securities, such as exchange-traded funds, that are linked to foreign currencies. In addition to the types of securities and investments described above, Guiry Capital Management may recommend investments in certain asset classes via private partnerships. Single Stock and Portfolio Risk Management Services: As part of its investment advisory services, Guiry Capital Management may advise certain clients on how to diversify concentrated stock positions, and how to manage single stock and/or portfolio risk exposure. For both nondiscretionary and discretionary investment advisory accounts, Guiry Capital Management tailors its investment recommendations and investment selections to meet clients’ asset allocation and investment objectives. Guiry Capital Management also allows clients to impose restrictions on investing in certain securities or types of securities. For both nondiscretionary and discretionary accounts, clients will give Guiry Capital Management the authorization in writing to execute trades and securities transactions on their behalf in the at a broker-dealer/custodian designated by the client. Guiry Capital Management’s investment advisory agreement, which serves as the contract between the Client and Advisor, specifies the nature of services to be rendered by Guiry Capital Management and the advisory fees to be paid by the client. Guiry Capital Management does not provide any “wrap programs” (programs that bundle brokerage and advisory services under a single comprehensive fee) so all securities recommended by Guiry Capital Management may include additional transaction charges by the Client’s broker- dealer/custodian separate from Sample Advisor’s advisory fees.