Firm Description Crimson Management was founded in 1996. Crimson Management provides both personalized confidential planning and investment management to individuals. Crimson Management’s accounts are managed on both discretionary and nondiscretionary bases. Among the services Crimson Management provides are: ♦ Assisting clients in determining overall financial goals and objectives ♦ Assessing risk tolerance ♦ Determining investment objectives in light of each client’s tax bracket, time requirements, investment experience, and retirement goals ♦ Determining optimal asset allocation among asset classes ♦ Researching investment vehicles, both public and private (private investments are nondiscretionary) ♦ Advising clients on selection of custodians ♦ Managing clients’ portfolios according to the client’s objectives ♦ Reviewing and monitoring clients’ accounts ♦ Meeting with clients Crimson Management is strictly a fee-only investment management and advisory firm. The firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. The firm is not affiliated with entities that sell financial products or securities. No commissions in any form are accepted. No finder’s fees are accepted. Crimson Management does not act as a custodian of client assets. The client always maintains asset control as Crimson Management places trades for clients under a limited trading authorization. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. The initial meeting, which can be by telephone, is free of charge and is considered an exploratory interview to determine the extent to which investment management can be beneficial to the client. Principal Owner Dean Putterman is the sole proprietor of Crimson Management. Types of Advisory Services Crimson Management provides investment supervisory services, also known as asset management services; manages investment advisory accounts not involving investment supervisory services; and furnishes investment advice through consultations. On more than an occasional basis, Crimson Management furnishes advice to clients on matters not involving securities, such as taxation issues. As of December 31, 2023, Crimson Management manages and advises approximately $380 million in assets; $173 million managed on a discretionary basis and $207 million managed on a nondiscretionary

basis. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system. Investment policy statements are created that reflect the stated goals and objectives. Clients can impose restrictions on investing in certain securities or types of securities. Investment Management Agreement The following agreement defines the typical client relationship. An Investment Management Agreement will be executed for all discretionary management accounts. Most clients choose to have Crimson Management manage their assets in order to obtain ongoing in-depth advice. All aspects of the client’s financial affairs are reviewed. Realistic and measurable goals are set and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The scope of work and fee for an Investment Management Agreement is provided to the client in writing prior to the start of the relationship. Although the Investment Management Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager can terminate an Agreement by written notice to the other party. At termination, fees will be billed on a prorated basis for the portion of the quarter completed. The portfolio value at the completion of the prior full billing quarter is used as the basis for the fee computation, adjusted for the number of days during the billing quarter prior to termination. Asset Management Stocks and bonds will be purchased or sold through a brokerage account when appropriate. The brokerage firm charges a fee for stock and bond trades. Crimson Management does not receive any compensation, in any form, from fund companies. Investments will include some of the following: equities (stocks), warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, mutual funds shares, U.S. government securities, ETFs, ETNs, and interests in partnerships. Termination of Agreement A client can terminate the aforementioned agreement at any time by notifying Crimson Management in writing and paying the rate for the time spent on the investment advisory engagement prior to notification of termination. If the client made an advance payment, Crimson Management will refund any unearned portion of the advance payment. Crimson Management can terminate the aforementioned agreement at any time by notifying the client in writing.