Firm Description SHAKER FINANCIAL SERVICES, LLC (SFS) is a Maryland limited liability corporation, formed on January 1, 2007, with operating offices in Maryland and Virginia. The predecessor management firm, Richard J. Shaker, DBA Shaker Financial Services, a sole proprietor, began full time operations on January 1, 1995, following Dr. Shaker’s retirement from the National Security Agency. SFS provides investment supervisory services on a discretionary basis, as stated in the investment advisory agreement. We manage investment accounts for clients, including individuals, families and their related entities, trusts, individual retirement accounts and small business retirement accounts. Account supervision is guided by the objectives of the client (e.g., maximum capital appreciation, growth, conservative growth) agreed upon through discussions between the client and SFS. Many of the securities SFS purchases are appropriate for accounts with differing objectives; thus individual accounts will have similar holdings even though the investment strategies may be different. Principal Owners The principal owners of the firm are Robert Shaker and Kathy Shaker Baummer. Types of Advisory Services SFS specializes in the trading of Closed-End Funds (CEFs). CEFs, like mutual funds or exchange traded funds, are investment companies that invest in a portfolio of securities. With rare exceptions, these portfolios are widely diversified within the asset class in which they invest. However, unlike mutual funds, and to a much greater extent than exchange traded funds, CEFs trade at varying discounts or premiums to the value of the securities they hold. Because CEFs specialize in equities, bonds, sectors, foreign markets or specific investment strategies, they are excellent vehicles for crafting portfolios that are balanced, diversified and have the particular risk level and market exposure that an individual client desires. Equally important is that the fluctuating discounts allow for the application of quantitative strategies that we believe will provide clients a return beyond that provided by the asset classes in which the funds they own invest. For each individual account, SFS maintains a globally diversified portfolio with a risk level based upon the client’s financial circumstances and individual preferences. The portfolios are comprised almost exclusively of CEFs. Each portfolio will have a specific target percentage allocation of each of the following: 1) equity funds, 2) bond funds, and 3) fixed income positions. Equity Funds: This portion of a client account is designed to provide the client exposure to US, global, and, when appropriate, emerging market equity markets. In general, this portion will provide market correlated growth, with, hopefully, an added return based on the effectiveness of SFS strategies. Examples of CEFs held in this portion of a client’s portfolio are those which specialize in domestic large caps, mid-caps or small-caps, high dividend paying equities, international or emerging markets equities, specific countries, specific regions or specific sectors (e.g., utilities, telecommunications, banking, healthcare) and real estate investment trusts. Although we strive to find good representatives from as many of these types of equity funds as possible, the size of the account, as well as our ability to find favorable purchases within a specific type of equity CEF, will mean that not all types of funds will be represented in each individual portfolio. We do enforce prudent limits to ensure that no account contains a large concentration of any one specific CEF or any one type of equity fund. Bond Funds: This portion of a client account is designed to

provide the client exposure to funds that hold fixed-income products. In general, this portion will provide the client income, with low or, in some instances, negative correlation to equity indices, with, hopefully, an added return based on the effectiveness of SFS strategies. Examples of CEFs held in this portion of a client’s portfolio are those that specialize in government bonds, investment grade bonds, high-yield bonds, international bonds, emerging market bonds, mortgage bonds, senior corporate commercial paper and preferred stock. Although we strive to find good representatives from as many types of funds as possible, the size of the account, as well as our ability to find favorable purchases within a specific type of bond CEF, will mean that not all types of funds will be represented in each individual portfolio. We do enforce prudent limits to ensure that no account contains a large concentration of any one specific CEF and any one type of bond fund. Fixed Income Positions (FIPs): These are specially selected to have little correlation with equity markets. Although they do not guarantee return of principal, they are a reasonable substitute for cash reserves for those who are willing to take a modicum of risk. They may also be bought on margin to take advantage of low margin interest rates available to SFS investors without adding significant new risk to a portfolio. In seeking investment choices for FIPs, we try to find special situations among CEF investments that have FIP characteristics (e.g. preferred shares of CEFs). If none are available, we may substitute other investment vehicles, such as short duration investment grade bonds or mutual funds containing short duration investment grade bonds. While the vast majority of client funds are invested in these areas, SFS retains the right to invest in any area, and based upon other strategies, when opportunities present themselves. Individually Tailored Services Before beginning management of any account, we gather pertinent financial information from the client. Examples of such information we attempt to obtain include the following: (1) age (2) future income prospects (3) total asset picture (4) risk level of investments the client is investing elsewhere (5) psychological risk tolerance (6) long-term investment goals (7) short-term need for funds We then discuss which of the five SFS Risk Levels is most appropriate for the account. The choice of risk level (or whether a unique set of parameters is assigned to an account) is ultimately made by the client after consultation with an adviser. A client may choose one mix for one account and another for another account, depending on the investment goals of each account. We encourage eligible (taxable) accounts to employ margin, or investing with borrowed funds, as we believe that it provides an opportunity to enhance returns. However, the use of margin is, generally speaking, a more aggressive, higher risk approach to pursuing investment objectives. Clients are afforded the opportunity to impose reasonable restrictions on their investments. Although most clients do not, examples of such reasonable instructions include a prohibition of investments in a sector (e.g., where the client already has large investments in this area), a prohibition of a particular CEF (e.g., one for which the client has had a bad experience), or a prohibition of a large list of CEFs (e.g., if an employer prohibits purchase of certain securities because of conflicts of interest). Assets Under Management As of December 31, 2023, SFS managed approximately $228 million on a discretionary basis for approximately 630 accounts or approximately 350 clients.