Firm Description Narwhal is an investment adviser providing investment advisory services to individuals, high net worth individuals, charitable organizations, corporations, private funds, and trusts. Narwhal was founded in 2005. Principal Owners Narwhal is owned by Matthew D. Burton, Managing Member and Founder. Types of Advisory Services Narwhal offers the following types of advisory services: Financial planning services, portfolio management for individuals and/or small business, and portfolio management for businesses or institutional clients, as well as pooled investment vehicles. Narwhal also provides services to 401(k) plans and plan sponsors. Investment Advisory Services Narwhal provides investment advisory services, defined as giving continuous advice to a client, and selecting investments for a client based on the individual needs of the client. Through personal discussions, goals and objectives are established based on a client’s particular circumstances. Narwhal assists the client in developing the client’s personal investment policy, and then creates and manages a portfolio based on that policy. Narwhal develops portfolios based upon a client’s goals, objectives, investment time horizon and risk tolerance, as well as their core financial-related values. Investment strategies generally include long-term and short-term purchases depending upon the individual needs of the client. Narwhal uses asset allocation or spreading investments among a number of asset classes and sectors (domestic stocks vs. foreign stocks; large cap stocks vs. small cap stocks; corporate bonds vs. government securities) for most client portfolios. On smaller portfolios, Narwhal may achieve diversification and minimize transaction costs by utilizing ETFs and mutual funds. Limited Investment Advisory Services Clients who do not desire extensive investment advisory services can secure such services on a consulting basis. In this case, Narwhal provides independent advice in regard to the overall portfolio, adherence to the client’s investment policy, and the money manager(s) performing the actual management of the portfolio. Narwhal will not provide advice regarding any specific security in the portfolio. Financial Planning Narwhal offers financial planning services, which may include a review of all aspects of a client’s current financial situation, including the following components: cash management, risk management, insurance, education funding, goal setting, retirement planning, estate and charitable giving planning, tax planning, and capital needs planning. Narwhal meets with the client to review risk tolerance, financial goals and objectives, and time horizons. Additional meetings may include a review of additional financial information; sources of income, assets owned, existing insurance, liabilities, wills, trusts, business agreements, tax returns, investments, and personal and family obligations. Financial planning services may be comprehensive or may focus on certain components. Clients understand that when Narwhal is engaged to address only certain components, the client’s overall financial and investment issues may not be taken into consideration. Private Fund Investments Narwhal acts as the Manager to The Sailfish Fund, LLC, (The Sailfish Fund or the Fund) a private investment fund in which certain clients invest. The Sailfish Fund invests in a variety of asset classes, including, but not limited to, stocks, bonds, and cash using a balanced approach. Additional information, including fees and specific procedures and restrictions for withdrawals from, and terminations of a position in the Fund are described in the Fund’s Private Placement Memorandum. Retirement

Plan Advisory Services Narwhal provides advisory services to retirement plans (each a “Plan”) and the company/sponsor of the Plan (the “Plan Sponsor”). Retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Tax and Accounting Services In certain circumstances, Narwhal will provide accounting services and prepare individual and corporate tax returns on behalf of clients. In addition, Narwhal may provide clients with consulting services on tax-related and other accounting matters. Tailored Relationships Narwhal tailors investment advisory services to the individual needs of the client. Narwhal’s clients are allowed to impose restrictions on the investments in their account. 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. Narwhal may accept any reasonable limitation or restriction to discretionary authority on the account placed by the client. All limitations and restrictions placed on accounts must be presented to Narwhal in writing. Wrap Fee Programs Narwhal does not participate in a Wrap Fee Program. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Client Assets As of December 31, 2022, we manage $1,296,346,813 in assets under management. $1,144,499,648 is managed on a discretionary basis, and $151,847,165 is managed on a non- discretionary basis.