Company Marathon Capital Management LLC ("Marathon") was established in 1998 as a sole proprietorship by James G. Kennedy to provide investment advisory services. Originally registered with the State of Maryland due to the amount of assets under management. It changed its corporate structure to a Limited Liability Corporation (LLC) in early 20002. In 2004 Marathon became a registered adviser with the Securities and Exchange Commission (SEC). Registration with the SEC does not imply a particular level of skill or training.
Marathon is owned by its principal, Angus M. Burton, who also serves as President, Clifford Athey, Partner, and Edward Hart, Partner.
Services Marathon provides investment management services to both individuals and organizations. It creates an Investment Profile for each client that summarizes the objectives and overall structure of the portfolio(s). There are five basic categories identified for portfolio management: Income, Growth and Income, Growth, all cap, concentrated growth and ETF. After discussions and meetings with prospective clients, we establish an Investment Profile that is signed by the client and becomes the general guideline for establishing and managing the portfolio(s). These portfolios are reviewed by the investment adviser representative on the account with the client periodically, but no less than annually. Although Marathon employs four basic categories to guide the firm in the management of client assets, each account is managed individually, based on each client's individual needs and circumstances. Therefore, advice provided to one client may differ from that provided to another client, based on each client's unique circumstances. Marathon is what is traditionally known as a "buy and hold" investment manager. We like to tell clients that if we buy something and sell it in less than a one-year timeframe, we've either made a mistake or the investment has exceeded our expectations. There will always be exceptions to the rule, but our focus is on long-term appreciation of capital, not short-term trading profits.
Marathon manages advisory accounts on a discretionary basis only. Clients can place reasonable restrictions on

the type of investments bought on their behalf.
Marathon also offers financial planning utilizing the MoneyGuidePro software. There is no extra or separate charge for this service as it is used as part of the client relationship. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours.
Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice); 4
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in yourbest interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from an ERISA account to an account that we manage or provide investment advice, because the assets increase our assets under management and our advisory fees. In contrast, we receive less or no compensation if assets remain in the current plan or are rolled over to another Company plan in which you may participate.
Regulatory Assets Under Management As of December 31, 2023, we provide continuous management services for $677,081,355 in client assets on a discretionary basis.