A. MV Capital Management Inc. (“MVCM”) is a Maryland corporation. Masood Vojdani is the sole owner of MVCM and has over 30 years of experience in the financial industry. At MVCM our mission is to provide unparalleled service, uncommon thinking and uncompromising standards in delivering investment management strategies and solutions tailored to the unique circumstances of each and every client.
• A client service approach that focuses on the specific, unique needs of each client and develops an investment policy customized to the client’s return objectives, risk tolerance and special circumstances.
• An in-house research and development practice aimed at distilling the complexities of the modern global capital marketplace into innovative, practical investment strategies and solutions.
• An independent advisory and execution platform from which to offer advice where our financial success is aligned with our clients. B. As discussed below, MVCM offers to its clients investment advisory services, and, to the extent specifically requested by a client, financial planning and related consulting services. INVESTMENT ADVISORY SERVICES Clients can engage MVCM to provide discretionary or non-discretionary investment advisory services on non-wrap fee basis. We generally manage portfolios on a discretionary basis, for which we would have the authority to buy and sell investments in your accounts without speaking to you before doing so. However, clients can place reasonable restrictions on the securities by notifying us, in writing. The client will select individual services on an unbundled basis, paying for each service separately (i.e. investment advisory, brokerage, custody). MVCM’s annual investment advisory fee shall include investment advisory services, and, to the extent requested by the client, financial planning and consulting services. In the event that the client requires extraordinary planning or consulting services (to be determined in the sole discretion of MVCM), MVCM can charge for these additional services, the dollar amount of which will be provided in a separate written notice to the client. NON-WRAP FEE BASIS Clients can engage MVCM to provide discretionary or non-discretionary investment advisory services. Generally, MVCM’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under MVCM’s management. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) To the extent requested by a client, MVCM may provide financial planning or consulting services (on investment and non-investment related matters, including estate planning and insurance planning) on a stand-alone separate fee basis. Prior to engaging MVCM to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with MVCM setting forth the terms and conditions of the engagement. MISCELLANEOUS ADVISORY SERVICES DISCLOSURE Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. If requested by the client, MVCM may provide financial planning and related consulting services regarding non-investment related matters, such as estate, tax and insurance planning either as part of the investment advisory engagement or according to the terms and conditions of a stand-alone Financial Planning and Consulting Agreement. Neither MVCM, nor any of its representatives, serves as an attorney or accountant and no portion of MVCM’s services should be construed as legal or accounting services. Unless specifically agreed in writing, neither MVCM nor its representatives are responsible to: implement any financial plans or financial planning advice; provide ongoing financial planning services; or provide ongoing monitoring of financial plans or financial planning advice. The client is solely responsible to revisit the financial plan or financial planning advice with MVCM, if desired. The client retains absolute discretion over all financial planning and related implementation decisions and is free to accept or reject any recommendation from MVCM and its representatives in that respect. MVCM’s financial planning and consulting services are completed upon communicating its recommendations to the client, upon delivery of the written financial plan, or upon termination of the applicable agreement. To the extent requested by a client, MVCM may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance, etc.), including certain of MVCM’s investment adviser representatives in their separate licensed capacities as discussed in Item 10.C. below. This presents conflicts of interest. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from MVCM. If the client engages any unaffiliated recommended professional, and a dispute arises related to the engagement, the client should seek recourse exclusively

from and against the engaged professional. Non-Discretionary Service Limitations. Clients that determine to engage MVCM on a non- discretionary investment advisory basis must be willing to accept that MVCM cannot effect any account transactions without obtaining the client’s consent. A client may suffer investment losses or miss potential investment gains should MVCM be unable to reach the client or if the client does not act on our recommendations for transactions where we do not have discretion. Retirement Rollovers. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If MVCM recommends that a client roll over their retirement plan assets into an account to be managed by MVCM, such a recommendation creates a conflict of interest if MCVM will earn an advisory fee on the rolled over assets. No client is under any obligation to roll over retirement plan assets to an account managed by MVCM. MVCM’s Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the conflict of interest presented by rollover recommendations. Independent Managers. MVCM may invest or recommend that the client invest using unaffiliated independent investment managers (“Independent Managers”) in accordance with the client’s designated investment objectives. In these situations, the Independent Manager has the day-to-day responsibility for the active discretionary management of the client’s assets. MVCM will continue monitor and review the client’s account performance, asset allocation and investment objectives. Factors that MVCM considers in recommending Independent Managers include the client’s designated investment objectives, and the manager’s management style, performance, reputation, financial strength, reporting capabilities, pricing structure, and published research. The investment management fees charged by the designated Independent Managers are exclusive of, and in addition to, MVCM’s ongoing investment advisory fee described in Item 5, which will be disclosed to the client before entering into the Independent Manager engagement and/or subject to the terms and conditions of a separate agreement between the client and the Independent Managers. Single Strategy Program. MVCM may also recommend that clients invest in one or more investment strategies offered in the Single Strategy Program (“SSP”) consistent with the client’s investment objectives and risk profile. Assets using a strategy in the SSP will be managed in a separate account from all other assets and strategies. Although the strategies used may be considered part of a client’s overall portfolio allocation, each strategy in the SSP is independently managed based on proprietary guidelines developed and implemented by MVCM. Client Obligations. MVCM will not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely on the information in its possession. Clients are responsible for promptly notifying MVCM if there is ever any change in their financial situation or investment objectives so that MVCM can review, and if necessary, revise its previous recommendations or services. Portfolio Trading Activity. As part of its investment advisory services, MCVM will review client portfolios on an ongoing basis to determine if any trades are necessary based upon various factors, including but not limited to investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when MCVM determines that trades within a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 during periods of portfolio trading inactivity. C. MVCM shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will determine each client’s investment objectives. Thereafter, MVCM will invest or recommend that the client invest their assets consistent with their investment objectives. Please see Item 8 for details regarding investment selection. The client may, at any time, impose reasonable restrictions, in writing, on MVCM’s services. D. As of December 31, 2023, MVCM had $1,066,929,248 in assets under management on a discretionary basis and $1,197,610 in assets under management on a non-discretionary basis.