Brighton Securities is a local, independently owned stock brokerage and financial services firm that was established in 1969. The firm is federally registered with the SEC as an investment advisor. Brighton Securities is also an SEC registered broker-dealer and member of the Financial Industry Regulatory Authority, Inc. (“FINRA”). It is a “full service” broker-dealer engaging in purchases and sales of exchange listed and other publicly traded securities as well as the sale of annuities and other insurance products. Brighton Securities’ investment advisory activities are undertaken in conjunction with other financial services offered to clients. Brighton Securities may recommend other professionals (e.g., lawyers, insurance agents, real estate agents, etc.) at the request of a client. Other professionals are engaged directly by the client on an as-needed basis even when recommended by a Brighton Securities financial advisor. Conflicts of interest will be disclosed to the client and managed in the best interest of the client. Principal Owners George T. Conboy is an 66.30% stockholder of Brighton Securities Holdings, Inc. which wholly owns Brighton Securities Corp. Brighton Securities offers the following advisory services to our clients: Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, we develop a client’s personal investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client’s prior investment history, as well as family composition and background. Brighton Securities provides non-discretionary and discretionary investment advisory services geared primarily to individuals, trusts, estates and small businesses that wish to have their accounts managed. Brighton Securities also offers fee-based financial planning, insurance products, and state and federal income tax preparation for a fee. Account supervision is guided by the client’s stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:  Exchange-listed securities  Exchange Traded Funds (ETF)  Securities traded over the counter  Corporate debt securities (other than commercial paper)  Commercial paper  Certificates of deposit  Municipal securities  Variable life insurance  Variable annuities  Mutual fund shares  United States governmental securities  Options contracts on securities  Other Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client’s stated investment objectives, tolerance for risk, liquidity and suitability. Types of Advisory Services offered include: Brighton Securities offers managed accounts services through the following programs: 1. Wells Fargo - Investment managers are selected from a group offered through Brighton Securities’ relationship with its clearing firm, Wells Fargo Clearing Services, LLC (“Wells Fargo Clearing”). 2. Proprietary Managed Account Program can be carried through BSC or Broker/Dealer of client’s choice. 3. Consulting Services The investment advisory programs

offered give clients the opportunity to obtain portfolio management services from a select, pre-screened group of investment managers. Pursuant to the programs, investment needs, objectives, and risk tolerance for each client is determined through a review of client completed documentation and in consultation with a Brighton Securities financial advisor. Clients retain the power to appoint and remove a chosen investment manager, at each client’s discretion. Brighton Securities may recommend that a client change a manager for any reason but does not assume responsibility for the client’s choice of manager or the manager’s performance, compliance with applicable laws and regulations, or other matters within the manager’s control. The Services Provided by each Program are as follows: 1. Wells Fargo – Brighton Securities has entered into an agreement with Wells Fargo Advisors, LLC (“WFA”), pursuant to which WFA provides advisory and/or other services with respect to certain managed account programs. Clients investing through investment advisory accounts described herein are clients of Brighton Securities. Brighton Securities is not related to or affiliated with WFA or Wells Fargo Clearing. Wells Fargo Clearing will maintain custody of client assets and it qualifies as a “qualified custodian” as described in Rule 206(4)-2 of the Investment Advisers Act. WFA and Wells Fargo Clearing each reserves the right to reject and not provide services to any client or with respect to any client account for any reason. WFA provides advisory and other services to Brighton Securities with respect to the following investment programs: Masters, Personalized UMA, Wells Fargo Compass, Allocation Advisors, Customized Portfolios, and FundSource. Clients should review the appropriate WFA disclosure documents for a complete description of each program. WFA does not provide portfolio management advisory services to Brighton Securities with respect to the following programs: Private Investment Management, Asset Advisor, and CustomChoice. WFA provides certain non-advisory services which enable Brighton Securities to offer these programs. 2. SAMI Proprietary Managed Account Program: The program utilizes any number of different open & closed end and exchange traded mutual funds, stocks and/or bonds. They are consolidated on one account statement. In addition to the management fee calculated on a percentage of assets under management, the B/D executing the orders may levy ticket charges as well as postage & handling fees on trades. While most clients utilize BSC as the B/D, other B/D's may be utilized at the client's discretion. Therefore, BSC may be acting in the capacity of both the investment advisor and the broker dealer of record. In addition, the client may incur exchange fees levied by the clearing firm. The purpose of this modification is to offer greater flexibility to clients in terms of providing aggressive, intermediate, conservative, or income accounts run under individually tailored programs for the specific client. (4) CONSULTING SERVICES Clients can also receive investment advice on a more focused basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, or any other specific topic. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. Consulting recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a generic nature. Managed Assets As of December 2023, Brighton Securities managed approximately $598,064,198 in assets for 2071 accounts. Approximately $322,367,779 is managed on a non-discretionary basis and $275,696,420 on a discretionary basis.