Firm Description TORTUGA ADVISERS LLC, was founded in 2005. TORTUGA ADVISERS LLC provides personalized and confidential investment management to individuals, trusts, estates, charitable organizations and pension and profit-sharing plans of small businesses. Advice is provided through personal consultation with the client. The primary focus of such consultation is investment management but typically includes other subjects such as updating financial objectives, constraints, and determination of cash flow requirements. These conversations often include discussions of education funding, estate planning and tax considerations. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest would be disclosed to the client in the unlikely event they should occur. TORTUGA ADVISERS LLC is committed to providing unbiased and independent advice. TORTUGA ADVISERS LLC is strictly a fee-only investment management firm. The firm does not receive commissions for purchasing or selling annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or any other product. 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 or paid. Investment advice is provided, with the client making the final decision on investment selection in most cases. However, TORTUGA ADVISERS LLC also manages a very small number of discretionary accounts. Should it be determined that immediate action needs to be taken across a number of portfolios clients will be contacted in a randomized order. TORTUGA ADVISERS LLC does not act as a custodian of client assets. The client always maintains asset control. TORTUGA ADVISERS LLC places trades for clients under a limited power of attorney. An evaluation of each client's individual situation is provided to the client, often in the form of personal discussions and an investment policy is agreed upon. Periodic reviews are also communicated to discuss specific changes that seem to be advantageous to the client. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. . Principal Owners Michael F Schaible owns all of the stock of TORTUGA ADVISERS LLC. Types of Advisory Services TORTUGA ADVISERS LLC provides advice about investments. Because most clients make the final decision on securities purchases the firm puts great emphasis explaining financial choices through individual consultation, which is also essential part of developing a personal understanding of each clients objectives and constraints. On more than an occasional basis, TORTUGA ADVISERS LLC furnishes background advice to clients on matters not involving securities, such as, insurance, estate planning and taxation. The firm seeks to coordinate with the client and the relevant professionals in those various fields. Such advice is provided as a matter of course, no additional fees are billed. As of December 31, 2022 TORTUGA ADVISERS LLC manages approximately $470 million in assets for approximately 40 clients. Approximately $40 million is managed on a discretionary basis, and $430 Million is managed on a non-discretionary basis. Tailored Relationships The

goals and objectives for each client are reached in our early discussions. Furthermore, asset allocation is a frequent discussion in client meetings to ensure that we continue to manage the client’s investment assets in accordance with their individual objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without client consent. Advisory Service Agreement Most clients choose to have TORTUGA ADVISERS LLC manage their assets in order to obtain ongoing in-depth advice. All aspects of the client’s financial affairs are reviewed, including those of their children. Realistic 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 Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. The annual Advisory Service Agreement fee is based on the complexity of the assignment. In general, annual fees are set a 0.75% of assets under management. In addition to complexity, the amount of assets to be managed influences the fee. Client relationships may exist where the fees are higher or lower than the fee schedule above. Fees are negotiable. Although the Advisory Service Agreement is an ongoing agreement it can be terminated by either party without cause by providing written notice to the other party. At termination, fees will be billed on a pro rata 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 Assets are primarily invested in stocks and bonds which are purchased or sold through a brokerage account when appropriate. The brokerage firm charges a fee for stock and bond trades. TORTUGA ADVISERS LLC does not receive any compensation, in any form, from fund companies. Investments may also include: equities (stocks), warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (variable life insurance, variable annuities, and mutual funds shares), U. S. government securities, options contracts, futures contracts, and interests in partnerships. Assets that are invested in mutual funds are primarily in no-load or low-load mutual funds and exchange-traded funds. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Initial public offerings (IPOs) are not available through TORTUGA ADVISERS LLC. Termination of Agreement A Client may terminate any of the aforementioned agreements at any time by notifying TORTUGA ADVISERS LLC 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, TORTUGA ADVISERS LLC will refund any unearned portion of the advance payment. TORTUGA ADVISERS LLC may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, TORTUGA ADVISERS LLC will refund any unearned portion of the advance payment.