9AT: LESA SROUFE & COMPANY, INC.

LESA SROUFE & COMPANY, INC.

LESA SROUFE & COMPANY, INC.

Adviser Profile

As of Date	03/26/2026
Registration	SEC, Approved, 01/03/2005
Other registrations (3)	California, Terminated, 01/27/2005 Idaho, Terminated, 01/27/2005 Washington, Terminated, 01/27/2005
ADV Location	SEATTLE, WA, United States
Contact Info	206 xxxxxxx
Websites

AUM^*	207,338,726 20%
of that, discretionary	199,078,961 22%
Number of Employees	4
of those in investment advisory functions	3
Private Fund GAV^*	0
Avg Account Size	871,171 23%
% High Net Worth	92.86% 128%
SMA’s	Yes
Private Funds	0

Adviser Type

- Large advisory firm

Client Types

- Individuals (other than high net worth individuals)
- High net worth individuals

Advisory Activities

- Financial planning services
- Portfolio management for individuals and/or small businesses
- Portfolio management for businesses
- Publication of periodicals or newsletters

Compensation Arrangments

- A percentage of assets under your management
- Fixed fees (other than subscription fees)

Reported AUM

230M 197M 164M 132M 99M 66M 33M

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026

Discretionary

Non-discretionary

Private Funds

No private funds

Employees

Top Holdings

Stock Ticker	Stock Name	$ Position	% Position	$ Change	# Change
Stck Ticker594918104	Stock NameMICROSOFT CORP COM	$ Position$8,797	% Position6.00%	$ Change-4.00%	# Change-5.00%
Stck Ticker651639106	Stock NameNEWMONT CORP COM	$ Position$7,850	% Position6.00%	$ Change-11.00%	# Change3.00%
Stck Ticker697900108	Stock NamePAN AMERN SILVER CORP COM	$ Position$6,746	% Position5.00%	$ Change-15.00%	# Change4.00%
Stck TickerG0378L100	Stock NameANGLOGOLD ASHANTI PLC COM SHS	$ Position$7,029	% Position5.00%	$ Change-15.00%	# Change3.00%
Stck Ticker40090E106	Stock NameGRUPO CIBEST SA FSPONSORED ADR 1 ADR REPS 4 ORD SHS	$ Position$5,465	% Position4.00%	$ Change13.00%	# Change3.00%
Stck Ticker46428Q109	Stock NameISHARES SILVER TRUST ETF	$ Position$5,318	% Position4.00%	$ Change-19.00%	# Change3.00%
Stck Ticker55261F104	Stock NameM & T BANK CORP	$ Position$5,968	% Position4.00%	$ Change12.00%	# Change-3.00%
Stck TickerY41053102	Stock NameINTERNATIONAL SEAWAYS INC COM	$ Position$4,720	% Position3.00%	$ Change9.00%	# Change3.00%
Stck Ticker71654V408	Stock NamePETROLEO BRASILEIRO S A SPONSORED ADR	$ Position$4,784	% Position3.00%	$ Change-20.00%	# Change3.00%
Stck Ticker75281A109	Stock NameRANGE RES CORP COM	$ Position$3,861	% Position3.00%	$ Change-15.00%	# Change3.00%

Brochure Summary

Overview

Lesa Sroufe & Company (“LSC”) is an SEC-registered investment adviser, founded in 2004, with i t s p r i n c i p a l business in S e a t t l e , WA. The fi rm ’s principal shareholder (controlling 25% or more of the company) is Lesa Sroufe (95% shareholder). The other employee-shareholder is Shaun Corry (5% shareholder). The Firm carries no debt and is 100% employee-owned. As of December 31, 2022, LSC managed $172,778,000; $162,627,000 on a discretionary basis, the remainder on a non-discretionary basis. LSC provides individual portfolio investment management using publicly traded companies, debt instruments and exchange-traded funds. Research-driven, LSC’s investment management focuses on individual selection of securities that are consistent with the firm’s Value Equity focus. LSC may also research and advise on equities previously acquired and currently owned by clients. All portfolios are managed on an individual basis, purchases and sales are entirely transparent. LSC is a top-down investor, starting with its outlook on the general economy. The portfolios are diversified, but focused, with between 25 and 35 individual stocks at any given time. The portfolios are also managed with the ability to hold cash,

up to 50% at the discretion of the CIO and the Research Director. LSC client accounts are either managed directly by LSC (“Direct Clients”) or sub- advised by LSC (termed a wrap-fee account). For sub-advised accounts LSC provides research, initiates and performs trading, and provides accounting and performance results, but does not have the primary relationship with the client. There is no difference between the portfolio management of the wrap-fee or sub-advised accounts and the directly managed accounts. Typically, compensation on these wrap-fee accounts consists of a share of the management fee, generally 50 basis points (0.50%). Two investment objectives available to LSC account holders are Equity Appreciation (equities) and Total Return (equities/bonds). This investment objective is established at the inception of the account. A target percentage in each asset class (equities, fixed income, and cash), given the client’s financial needs, objectives, age and experience, is also established. LSC offers all client accounts the opportunity to impose restrictions on specific equities and types of securities. Investment objectives, target asset allocations, and restrictions can be changed or modified at the client’s direction.